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Data Privacy International Data Transfers National Security

Venable LLP

DOJ Data Security Program Key Developments: A 90-Day "Good Faith" Extension, Compliance Guide, and Extensive FAQs

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On April 11, the Department of Justice's National Security Division (NSD) published new guidance on recent measures to restrict the ability of adversarial foreign governments and other foreign entities of concern to access...more

ArentFox Schiff

Navigating the DOJ’s New Data Transfer Rule: Implications and Compliance Requirements

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On January 8, the US Department of Justice (DOJ) issued a final rule under Executive Order 14117, which established the Rule Preventing Access to US Sensitive Personal Data and Government-Related Data by Countries of Concern...more

Clark Hill PLC

DOJ implements new rule restricting bulk transfers of sensitive personal data

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On April 22, FTC Commissioner Melissa Holyoak delivered the opening keynote at the IAPP Global Summit, where she emphasized the importance of vigorously enforcing privacy laws while warning against stretching the FTC’s...more

Paul Hastings LLP

Department of Justice Provides New Guidance on Bulk Sensitive Data Transfer Rules

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The Department of Justice’s National Security Division (NSD) released several documents on April 11, 2025, to assist entities that must comply with the Final Rule regulating or prohibiting the transfer of bulk U.S. sensitive...more

DLA Piper

US: Department of Justice Issues Final Rule Restricting the Transfer of Sensitive Personal Data and United States...

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On April, 8 2025, the Department of Justice’s final rule, implementing the Biden-era Executive Order 14117 restricting the transfer of Americans’ Sensitive Personal Data and United States Government-Related Data to countries...more

Dorsey & Whitney LLP

DOJ Limits Enforcement During First 90 Days of US-China Data Export Rules

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In a Press Release issued April 11, 2025, the U.S. Department of Justice (“DOJ”) indicated that it would prioritize “facilitating compliance” over civil enforcement actions for the first 90 days of its new US-China data...more

Snell & Wilmer

Restricting Bulk Data Transfers: Insights into the Final Rule

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A new U.S. federal rule restricts bulk sharing of sensitive personal information and governmental information with certain countries, for some key industries. In December 2024, the Department of Justice issued a comprehensive...more

Baker Donelson

DOJ Final Rule Targets Cross-Border Data Transfers: Key Implications for U.S. and Foreign-Owned Companies Operating in the U.S.

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In the final days of the Biden administration the U.S. Department of Justice (DOJ) issued a sweeping set of regulations which are in effect as of yesterday, April 8, 2025. The regulations focus on cross-border data transfers...more

Dacheng

A Practical Review of China's Restrictions on Cross-Border Transfer of Personal Information: Developments and Framework

Dacheng on

The cross-border transfer of personal information (hereinafter referred to as “PI,” and such transfers as “PI export”) is a routine and often essential part of business operations for companies in China—particularly...more

Miller Canfield

DOJ Rule Restricting Sensitive Data Transfers Takes Effect

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Today, April 8, 2025, the U.S. Department of Justice’s Final Rule restricting transfers of bulk sensitive personal data and U.S. government-related data becomes effective, implementing former President Biden’s Executive Order...more

Lathrop GPM

New DOJ Limits on Cross-Border Data Transfers Prompt Assessment by Businesses

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On April 8, the National Security Division of the U.S. Department of Justice’s (DOJ) new rule on cross-border data transfers takes effect. It restricts U.S. businesses from transferring certain bulk sensitive personal data to...more

Latham & Watkins LLP

Kingdom of Saudi Arabia Issues New Data Transfer Risk Assessment Guidelines

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The guidelines specify the requirements for data controllers to conduct risk assessments related to the transfer or disclosure of personal data outside the Kingdom. ...more

Venable LLP

A Brave New World: Four Considerations When Building a Bulk Data Rule Compliance Program

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U.S. companies and organizations have entered a new era of sweeping restrictions on cross-border data transfers. The Department of Justice's (DOJ) Final Rule, "Preventing Access to U.S. Sensitive Personal Data and...more

Troutman Pepper Locke

Do You Know Where Your Data Is Going? On April 8, New National Security Rules Take Effect

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A groundbreaking new regulatory regime, imposing rules unlike any in existing U.S. law, may surprise many companies due to its sudden adoption and complexity. This article tries to simplify the changing regulatory landscape,...more

Kilpatrick

DOJ Final Rule on Bulk Data Transfers Implements New Restrictions on Transferring Personal Data Out of the United States

Kilpatrick on

The U.S. Department of Justice (DOJ) has issued a final rule that significantly restricts the transfer of bulk sensitive personal data and government-related data to certain foreign entities deemed countries of concern....more

WilmerHale

DOJ Finalizes Rule Regarding Sensitive Data Transfers

WilmerHale on

On January 8, the Department of Justice (DOJ) published its final Rule implementing Executive Order 14117 (EO), “Preventing Access to Americans’ Bulk Sensitive Personal Data and United States Government-Related Data by...more

Orrick, Herrington & Sutcliffe LLP

US Data Localization Law Coming Soon: DOJ Issues Final Rule on Certain Data Transfers to “Countries of Concern”

The Department of Justice has finalized prohibitions and restrictions on cross-border transfers of certain data to China and other “Countries of Concern” (as defined below). It seeks to address what is, in the U.S....more

Jones Day

Justice Department Issues Final Rule on Bulk Transfers of Sensitive Personal Data to Certain Countries

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The final rule establishes prohibitions and restrictions on the transfer of certain data due to national security risks from specified countries of concern....more

Hogan Lovells

DOJ restricts data transfers to protect national security; research exemptions expanded in final rule

Hogan Lovells on

The U.S. Department of Justice (DOJ) has finalized its rule on “Preventing Access to U.S. Sensitive Personal Data and Government-Related Data by Countries of Concern or Covered Persons,” which restricts data brokerage...more

Dorsey & Whitney LLP

Justice Issues Final Rule Restricting Transfer of Personal U.S. Data to Countries of Concern, Effective in April 2025

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The U.S. Department of Justice (“DOJ”) published its final rule (“Final Rule”) on January 8, 2025, that will prohibit or restrict transfer of certain data of U.S. persons to countries of concern, including to China. The Final...more

Goodwin

Access Restricted: DOJ Prohibits or Restricts Data Sharing with China, Russia, and Other Specified Countries

Goodwin on

On December 27, 2024, the US Department of Justice (DOJ) issued a final rule establishing a new national security program to prevent access to Americans’ bulk sensitive personal data and government-related data by China...more

Ropes & Gray LLP

DOJ Issues Final Rule Restricting Flow of Bulk Sensitive Personal Data to China and Other Countries of Concern

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On January 8, 2025, the Department of Justice (“DOJ”) published its Final Rule to implement President Biden’s Executive Order 14117, “Preventing Access to Americans’ Bulk Sensitive Personal Data and United States...more

Fisher Phillips

The Clock is Ticking on TikTok – How Employers Can Prepare for TikTok Ban

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Employers and businesses are in limbo on how to prepare for a post-TikTok world after Congress passed legislation giving the social media app’s Chinese owner nine months to either sell the company or be banned throughout the...more

White & Case LLP

New Executive Order Seeks to Protect Americans' Sensitive Personal Data

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On February 28, 2024, President Biden signed Executive Order 14117 on "Preventing Access to Americans' Bulk Sensitive Data and United States Government-Related Data by Countries of Concern" (the EO).1 The EO calls for the...more

Fisher Phillips

New Executive Order to Block Businesses From Transferring Data to China and Other Countries of Concern – 4 Steps to Comply

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President Biden just issued an Executive Order that will lead to new restrictions on transferring sensitive personal data to China and other “countries of concern” – and it may create massive new compliance obligations for...more

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