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Episode 366 -- DOJ Issues Data Security Program 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
On April 11, 2025, the Department of Justice (DOJ) issued guidance (Guidance) to assist individuals and entities in coming into compliance with its final rule, referred to as the "Data Security Program" (DSP Rule), which...more
Many “good government” initiatives continue to be enacted or implemented on Capitol Hill or in the Executive Branch — notwithstanding changes in political control. While working on Capitol Hill, the bulk of the legislative...more
On January 20, 2025, an executive order froze two new pieces of proposed employee stock ownership plan (ESOP) guidance announced in a notice of proposed rulemaking and originally set for publication in the Federal Register on...more
On October 28, 2024, the U.S. Department of Treasury (Treasury Department) published a final rule (Final Rule) setting forth the regulations implementing Executive Order 14150 of August 9, 2023 (Outbound Investment Order),...more
The U.S. Department of Labor (DOL) on Jan. 16, 2025, released its long-awaited proposed regulation interpreting the definition of "adequate consideration" as applied to private company stock acquired or sold by an employee...more
On January 16, 2025, the US Department of Labor’s (DOL) Employee Benefits Security Administration (EBSA) released two pieces of guidance that, if finalized, would dramatically change the landscape for fiduciaries responsible...more
On January 2, 2025, the U.S. Department of the Treasury’s Final Rule on outbound investment screening became effective. The Final Rule implements Executive Order 14105 issued by former President Biden on August 9, 2023, and...more
On Friday, December 27, 2024, the Justice Department issued a final rule to address “urgent national security risks posed by access to U.S. sensitive personal and government-related data from countries of concern and covered...more
The U.S. Department of Commerce’s Bureau of Industry and Security (BIS), issued its much anticipated Final Rule under Executive Order 13873, Securing the Information and Communications Technology and Services Supply Chain (EO...more
On October 29, 2024, the U.S. Department of Justice (DOJ) published a proposed rule (Proposed Rule) that would restrict or prohibit certain transactions with China, Russia and other countries of concern involving U.S....more
On November 15, the U.S. Department of the Treasury published final regulations to implement its long-awaited “Outbound Investment” Security Program, which the Biden Administration originally introduced in August 2023 under...more
The Final Rule prohibits or requires notification of certain US investments in Chinese and Chinese-controlled entities involved in semiconductors, quantum information technologies, and artificial intelligence....more
On October 29, 2024, the Department of Justice (“DOJ”) published its Notice of Proposed Rulemaking (“NPRM”) to implement President Biden’s Executive Order 14117, “Preventing Access to Americans’ Bulk Sensitive Personal Data...more
The U.S. Department of Commerce's Bureau of Industry and Security (BIS) issued a Notice of Proposed Rulemaking (Proposed Rule) on Sept. 26, 2024, to address certain undue or unacceptable risks identified in Executive Order...more
The proposed regulations would implement President Biden’s Executive Order that restricts certain outbound investments from the US. On June 21, 2024, the US Department of the Treasury (Treasury) issued a Notice of Proposed...more
Last week, the Secretary of the Treasury released a final proposed rule to implement the Biden administration’s August 2023 Executive Order on outbound investments. The proposed rule seeks to “prevent countries of concern...more
On 21 June 2024, the Office of Investment Security of the US Department of the Treasury (Treasury) issued proposed regulations to implement President Biden’s August 2023 Executive Order on Addressing United States Investments...more
In response to Russia’s invasion of Ukraine, the U.S. government has deployed a whole-of-government approach to impose sanctions and tighter export controls on Russia. ...more
The Biden Administration recently issued an Executive Order aimed at protecting American’s sensitive information and certain US Government data from threats posed by foreign actors. Of note is the Order’s focus on data...more
In a sweeping, coordinated effort across federal agencies, the US government has taken a giant leap forward to prevent access to data that could be exploited to the detriment of national security. On February 28, 2024,...more
On February 28, 2024, President Biden announced that he was issuing an Executive Order (the "EO") directing the promulgation of regulations to limit the dissemination of "bulk sensitive personal data" and "United States...more
On February 28, 2024, the Biden administration announced new cybersecurity-related measures, including an executive order (EO) and advance notice of proposed rulemaking (ANPRM), intended to address the bulk flow of Americans’...more
Key Points - On December 22, 2023, President Biden issued E.O. 14114 “Taking Additional Steps With Respect to the Russian Federation’s Harmful Activities.” Specifically, E.O. 14114, which amends E.O. 14024 and E.O. 14068,...more
On August 9, 2023, the Biden Administration took the first significant steps towards implementing a new regime to restrict and regulate U.S. investments in certain Chinese technology sectors. The President released...more