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White & Case LLP

DOJ Issues Guidance on Bulk Sensitive Data Rules

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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

Womble Bond Dickinson

DOJ’s Data Security Program Final Rules Effective - Implications for Telecom Providers

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On January 8, 2025, the U.S. Department of Justice (DOJ) issued its final rule to implement Executive Order 14117 aimed at preventing access to Americans' bulk sensitive personal data and government-related data by countries...more

Troutman Pepper Locke

Inside New Commerce Tech Restrictions: Mitigation Strategies

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The U.S. Department of Commerce’s Bureau of Industry and Security has issued the final rule that will determine how its Information and Communications Technology and Services regulations will work going forward....more

Troutman Pepper Locke

Inside New Commerce Tech Restrictions: Key Risk Takeaways

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The U.S. Department of Commerce’s Bureau of Industry and Security has issued the final rule that will determine how its Information and Communications Technology and Services regulations will work going forward. Originally...more

Womble Bond Dickinson

Navigating the New DOJ Data Security Program Compliance

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On January 8, 2025, the U.S. Department of Justice (“DOJ”) issued its final rule to implement Executive Order 14117 aimed at preventing access to Americans' bulk sensitive personal data and government-related data by...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

Ropes & Gray LLP

DOJ Releases FAQs and Compliance Guidance for Final Rule Restricting Flow of Bulk Sensitive Personal Data to China and other...

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On April 11, 2025, the Department of Justice (“DOJ”) released additional detail regarding the Final Rule implementing former President Biden’s Executive Order 14117, “Preventing Access to Americans’ Bulk Sensitive Personal...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

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

McDermott Will & Emery

Special Report - Navigating the DOJ’s Final Rule on Preventing Access to Bulk US Sensitive Data by Countries of Concern

The US Department of Justice’s (DOJ’s) Final Rule on preventing access to US sensitive personal data, published in the Federal Register on January 8, 2025, will prohibit or significantly restrict the transfer of or other...more

Proskauer Rose LLP

The DOJ’s Final Rule on Access to U.S. Sensitive Personal Data and Government-Related Data by Countries of Concern or Covered...

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On December 27, 2024, the Department of Justice (the “DOJ”) issued its final rule (the “Rule”) carrying out Executive Order 14117 “Preventing Access to Americans’ Bulk Sensitive Personal Data and United States...more

Troutman Pepper Locke

New DOJ National Security Division Data Security Rules Take Effect on April 8: Is Your Organization Exposed?

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Under the Department of Justice’s (DOJ) “Preventing Access to U.S. Sensitive Personal Data and Government-Related Data by Countries of Concern or Covered Persons” rules (the Rules), allowing access outside the United States...more

Wiley Rein LLP

Update: DOJ and CISA Issue New National Security Program to Regulate Foreign Access to Sensitive Data

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On January 8, 2025, the U.S. Department of Justice (Department or DOJ) issued new rules required by then-President Biden’s February 2024 Executive Order (EO) 14117 to establish a new regulatory framework aimed at “Preventing...more

Perkins Coie

New US Commerce Prohibitions on Chinese and Russian Connected Vehicle Technology

Perkins Coie on

New security rules designed to protect the connected vehicle supply chain will take effect in March unless they are withdrawn. The U.S. Department of Commerce Bureau of Industry and Security (BIS) published the final rule...more

Robinson & Cole LLP

Legal Update: Final Rule Implementing U.S. Outbound Investments Restrictions Goes into Effect

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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

Wilson Sonsini Goodrich & Rosati

New BIS Rule Expands Export Controls and Due Diligence Requirements for Advanced Computing Integrated Circuits

As part of its ongoing efforts to thwart China's development of advanced computing technologies, the U.S. Department of Commerce's Bureau of Industry and Security (BIS) issued an interim final rule (the IFR) last month that...more

Morgan Lewis

Smartphones on Wheels: Commerce Issues Game-Changing Final Rule on Securing the ICTS Supply Chain in Connected Vehicles

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The US Department of Commerce’s Bureau of Industry and Security (BIS) published a Final Rule on January 16, 2025 that prohibits the import, sale, and manufacture of vehicles equipped with Vehicle Communication Systems (VCS)...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

Akin Gump Strauss Hauer & Feld LLP

Connected Vehicles Rule to Disrupt Supply Chain and Impose Compliance Obligations

On January 16, 2025, the Bureau of Industry and Security (BIS) published the Final Rule, prohibiting the import of “vehicle connectivity system” (VCS) hardware (including connected vehicles integrating that hardware) and the...more

WilmerHale

BIS Issues Export Control Compliance Requirements for Semiconductor Fabricators

WilmerHale on

On January 15, 2025, BIS issued an interim final rule controls targeting integrated circuits (“ICs”) fabricators. BIS is concerned that some IC designers have misrepresented the performance capabilities and intended end use...more

WilmerHale

BIS Issues the Final Connected Vehicles Rule, But Trump’s Recent Presidential Action Throws Implementation into Question

WilmerHale on

On January 14, 2025, BIS released the final rule for Securing the Information and Communications Technology and Services Supply Chain: Connected Vehicles (Connected Vehicle Rule). The Connected Vehicle Rule prohibits imports...more

Foley Hoag LLP

Understanding the U.S.’s New Outbound Investment Rules - January 2025

Foley Hoag LLP on

Effective in January 2025, the U.S. Department of the Treasury issued a final rule (colloquially known as “Reverse CFIUS”) implementing the Outbound Investment Program, which prohibits U.S. persons from making certain...more

Seward & Kissel LLP

New Restrictions on Investments into Chinese Entities: Considerations for Advisers, Private Funds, and Investors

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U.S. law has long subjected foreign investments into the U.S. to review and restriction by the Committee on Foreign Investment in the United States (“CFIUS”), but outside of economic sanctions programs, has typically not...more

Sheppard Mullin Richter & Hampton LLP

Data, Deals, and Diplomacy, Part III: DOJ Issues National Security Final Rule with New Data Compliance Obligations for...

On January 8, 2025, the Department of Justice (“DOJ”) published its final rule addressing Executive Order (E.O.) 14117, “Preventing Access to Americans’ Bulk Sensitive Personal Data and United States Government-Related Data...more

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