News & Analysis as of

International Data Transfers Regulatory Requirements

Bass, Berry & Sims PLC

DOJ Publishes Final Rule Restricting Bulk Cross-Border Data Transfers of Sensitive Data to Foreign Persons

On April 8, the U.S. Department of Justice’s (DOJ) Final Rule, codified at 28 CFR Part 202, (Final Rule), implementing President Biden’s Executive Order 14117 “Preventing Access to U.S. Sensitive Personal Data and...more

Seward & Kissel LLP

DOJ Implements New Data Security Program: Data Transfer Restrictions with a National Security Focus

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Effective as of April 8, 2025, the National Security Division of the U.S. Department of Justice (DOJ) has implemented a Data Security Program (the DSP) to address national security risks associated with the transfer of...more

Morris, Manning & Martin, LLP

Privacy Health Checkup

Are you using artificial intelligence in your business operations? Do you have AI embedded in the goods and services you offer customers? The regulatory framework applicable to AI continues to develop, including across US...more

Jackson Lewis P.C.

DOJ New Data Transfer Rule Impacts Hiring Practices, Business Operations, and Vendor Management: Time to Review Your Privacy +...

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U.S. organizations should carefully review and ensure their privacy and cybersecurity practices comply with a wide-ranging new federal rule establishing data transfer restrictions regarding sensitive U.S. personal data. The...more

Amundsen Davis LLC

Is My U.S.-Based Company Subject to the GDPR? Clearing Up European Data Privacy Law Misinformation

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If you are a compliance professional for a U.S.-based company, you have probably been told at some point that you have to worry about the General Data Protection Regulation (GDPR). Have you encountered one of these...more

DLA Piper

China: CAC Publishes Official Q&As for Cross-Border Data Transfer Regulation

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The Cyberspace Administration of China (CAC) released an important Q&A on cross-border data transfer requirements and policies in early April, providing clarification on a number of issues of concern to companies in China....more

Latham & Watkins LLP

Preparing for the European Health Data Space - Opportunities and Challenges for Europe’s Digital Future

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The EU regulation designed to facilitate secondary use of clinical data for research brings benefits for health research, but also poses challenges for companies....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

BakerHostetler

DOJ Implements Bulk Personal Data Transfer Restrictions

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The Data Security Program (DSP) recently implemented by the U.S. Department of Justice (DOJ) will have far-reaching implications for many businesses that transfer the personal data of U.S. citizens outside the United States....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

Littler

DOJ Rule Implementing Executive Order 14117 Regulating Cross-Border Data Transfers Takes Effect

Littler on

DOJ rule to implement Executive Order 14117, which restricts the exchange of sensitive personal data with certain “countries of concern,” took effect April 8. The order, which was issued under the prior administration,...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

Goodwin

DOJ’s Data Export Rule Is In Force April 8: What You Need to Do

Goodwin on

On April 8, 2025, a sweeping rule issued by the US Department of Justice (DOJ) will take effect. The rule imposes restrictions—and in some cases, outright prohibitions—on US companies in connection with certain types of data...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

Data in the Balance: Political Influence on EU-U.S. Data Transfers

In politically uncertain times, is your organisation’s data transfer compliance unquestionable? The EU-U.S. Data Privacy Framework (DPF) serves as a useful mechanism for transatlantic data transfers, and it can assist...more

Morgan Lewis

Key Considerations for Foreign Clinical Trials When Looking Abroad for Product Development

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With the continuing cuts to US Food and Drug Administration (FDA) staffing, the pharmaceutical and biotechnology industries are communicating increasing concern about potential product development impacts. While these cuts...more

Dacheng

China Monthly Data Protection Update: March 2025

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This monthly report outlines key developments in China’s data protection sector for March. The following events merit special attention...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

Constangy, Brooks, Smith & Prophete, LLP

Chile brings its data privacy laws in line with global data privacy standards

Chile has amended its data privacy law granting significant rights to data subjects, and imposing stricter obligations on data controllers and processors. Published in the Official Gazette (Diario Oficial) on December 13,...more

Sheppard Mullin Richter & Hampton LLP

Draft Measures for Personal Information Protection Certification for Cross-Border Data Transfers Released for Public Comment

On January 3, 2025, the Cyberspace Administration of China (the “CAC”) released the Draft Measures for Personal Information Protection Certification for Cross-Border Data Transfers (the “Draft Measures”) for public comment....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

A&O Shearman

CNIL publishes Data Transfer Impact Assessment guide

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On January 31, 2025, the French supervisory authority (CNIL) published the final version of its guide on transfer impact assessments (TIA). A TIA must be undertaken by organisations relying on one of the ‘appropriate...more

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