News & Analysis as of

Final Rules Regulatory Requirements Data Security

Bricker Graydon LLP

COPPA 2.0: The Remake

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After the Children’s Online Privacy Protection Rule (COPPA) updates, proposed by the FTC’s Final Rule, were paused due to an Executive Order in January this year, many wondered whether that would be the end of the long...more

Baker Donelson

DOJ Final Rule Applies to Anonymized, Pseudonymized, and De-Identified Data: What Data Licensors Need to Know

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What's Changed? The U.S. Department of Justice (DOJ) published a Data Security Program (DSP), pursuant to a final rule (Final Rule), which became effective on April 8, 2025....more

Baker Donelson

DOJ Issues Additional Guidance and Clarification on the Bulk Data Transfer Rule: What U.S. Businesses Need to Know

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On April 11, 2025, the Department of Justice's National Security Division (NSD) issued additional guidance to assist U.S. organizations in understanding and complying with the Data Security Program (DSP). As discussed in our...more

Jenner & Block

Client Alert: New Rules for Data Flows Take Effect: What You Need to Know

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On April 8, 2025, the United States Department of Justice’s (DOJ) National Security Division’s (NSD) final rule (Final Rule) regulating certain sensitive US data transfers took effect. DOJ has made clear that it will take...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...

DLA Piper on

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

Davis Wright Tremaine LLP

DOJ Issues Guidance on Foreign Data Access Rule, Announces Conditional 90-Day Enforcement Pause for "Good Faith Efforts"

The Department of Justice (DOJ) has issued guidance on its recently effective rule targeting foreign adversaries that "use commercial activities to access, exploit, and weaponize U.S. Government-related data and Americans'...more

Mayer Brown

Department of Justice Releases Compliance & Enforcement Guidance on Data Security Program

Mayer Brown on

On April 11, 2025, the Department of Justice (DOJ) announced additional guidance regarding the implementation of the Final Rule (the “Rule”), Provisions Pertaining to Preventing Access to U.S. Sensitive Personal Data and...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

White & Case LLP

DOJ Issues Final Rule Prohibiting and Restricting Transfers of Bulk Sensitive Personal Data

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The Department of Justice (DOJ) issued a final rule (the "Rule") on December 27, 2024, implementing Executive Order 14117 "Preventing Access to Americans' Bulk Sensitive Personal Data and United States Government-Related Data...more

Akin Gump Strauss Hauer & Feld LLP

DOJ Regulations Will Restrict Data Transactions to Address National Security Concerns

The Department of Justice’s (DOJ) final rule implements President Biden’s Executive Order 14117 of February 28, 2024, on “Preventing Access to Americans’ Bulk Sensitive Personal Data and United States Government-Related Data...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

Paul Hastings LLP

DOJ and CISA Issue Proposed Rules Regulating Export of Bulk Sensitive Data

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The Department of Justice (DOJ) released a Final Rule restricting certain transfers of Americans’ sensitive personal data to identified countries of concern or covered individuals. The Final Rule continues to assert the DOJ...more

Wilson Sonsini Goodrich & Rosati

The Busy Lawyer’s Guide to the New “Data Export Control” Rules

On January 8, 2025, the U.S. Department of Justice (DOJ) published final rules (the Final Rules) to prohibit or restrict transactions by U.S. persons that could result in access to sensitive data by persons associated with...more

Arnall Golden Gregory LLP

Access to U.S. Sensitive Personal Information and Government Related Data by Countries of Concern or Covered Persons Subject to...

The Department of Justice (“DOJ”) published its final regulations on “Preventing Access to U.S. Sensitive Personal Data and Government-Related Data by Countries of Concern or Covered Persons” (the “Final Rule”). The Final...more

Skadden, Arps, Slate, Meagher & Flom LLP

FTC Finalizes Long-Awaited Child Online Privacy Rule Amendments

On January 16, 2025, the Federal Trade Commission (FTC) finalized amendments to the Children’s Online Privacy Protection Act (COPPA) Rule (Final Rule) relating to the collection, use and disclosure of personal information...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

Buchalter

Significant New HIPAA Obligations on Their Way for 2025

Buchalter on

The Department of Health & Human Services (HHS) issued proposed changes to the HIPAA Security Rule (“Proposed Rule”) on January 6, 2025, and is accepting comments from the public until March 7, 2025. The Proposed Rule...more

Perkins Coie

DOJ’s Final Rule on Data Transfers: Impacts Across Industries

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As of January 23, 2025, the regulation discussed below has not been withdrawn by the Trump administration and is not subject to automatic withdrawal under President Trump’s Executive Order freezing regulations. It currently...more

WilmerHale

DOJ Finalizes Rule Regarding Sensitive Data Transfers

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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

Venable LLP

DOJ Issues Final Rule on Bulk Sensitive Personal Data

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On January 8, 2025, the Department of Justice (DOJ) published in the Federal Register a Final Rule, "Preventing Access to U.S. Sensitive Personal Data and Government Related Data by Countries of Concern or Covered Persons,"...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

A&O Shearman

DOJ/CISA finalize new rules regarding data transfers to countries of concern

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On December 27, 2024, the U.S. Department of Justice (DOJ) announced its final rule on the transfer of certain bulk sensitive personal data to China, Russia, and other countries. Following this, on January 3, 2025, the U.S....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

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