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International Data Transfers Regulatory Requirements China

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

Seward & Kissel LLP on

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

Jackson Lewis P.C.

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

Jackson Lewis P.C. on

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

DLA Piper

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

DLA Piper on

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

Snell & Wilmer

Restricting Bulk Data Transfers: Insights into the Final Rule

Snell & Wilmer on

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.

Baker Donelson on

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

Dacheng

China Monthly Data Protection Update: March 2025

Dacheng on

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

Troutman Pepper Locke on

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

Dorsey & Whitney LLP

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

Dorsey & Whitney LLP on

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

DLA Piper

CHINA: Draft Regulation on Certification for Cross-Border Data Transfers Published

DLA Piper on

On 3 January 2025, the Cyberspace Administration of China (“CAC“) released for public consultation the draft Measures for Certification of Personal Information Protection for Cross-Border Transfer of Personal Information...more

Mayer Brown

PRC Network Data Security Management Regulations

Mayer Brown on

On 30 September 2024, the State Council of the People's Republic of China published the Network Data Security Management Regulations (the “Regulations”).1 These Regulations finalise the Draft Regulations released for public...more

Skadden, Arps, Slate, Meagher & Flom LLP

Fortifying US Data: Proposed Rule Would Establish a New Regime To Restrict or Prohibit Certain Data Transactions With Countries of...

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

A&O Shearman

EU Foreign Subsidy Regulation: General Court refuses to suspend EC request for mailboxes located in China

A&O Shearman on

In the context of a dawn raid under the EU Foreign Subsidy Regulation (FSR), the EU General Court (GC) has refused to suspend the European Commission (EC)’s request to access employees’ mailboxes located in China....more

DLA Piper

CHINA: Mandatory Data Protection Compliance (Self) Audits on Their Way

DLA Piper on

The Personal Information Protection Law (“PIPL“) requires a data controller to conduct compliance audits of its personal data processing activities on a regular basis (“Self-supervision Audits“). Apart from such...more

White & Case LLP

China Released New Regulations to Ease Requirements for Outbound Cross-Border Data Transfers

White & Case LLP on

On March 22, 2024, the Cyberspace Administration of China (the "CAC") issued the highly anticipated final Regulations on Promoting and Regulating Cross-Border Data Flows (the "Regulations on Cross-Border Data Flows"),...more

Benesch

China Officially Promulgates New Cross-Border Data Transfer Requirements

Benesch on

The newly promulgated measures increase the threshold of data triggering security assessments and contract requirements while leaving room for Chinese authorities to heavily restrict cross-border data transfers. In...more

WilmerHale

China Publishes Draft Regulations on the Administration of Network Data Security

WilmerHale on

The Cyberspace Administration of China (“CAC”) on November 14, 2021 published the draft Regulations on the Administration of Network Data Security (“Draft Regulations”) for comment through December 13, 2021.1 The Draft...more

Jones Day

China Issues Draft Guidance on Security Assessments for Cross-Border Data Transfers

Jones Day on

The Cyberspace Administration of China has issued draft guidance on applying for and conducting security assessments for cross-border data transfers for public comment. On October 29, 2021, the Cyberspace Administration of...more

Polsinelli

Five Immediate Steps to Take in Preparation for China’s New Comprehensive Privacy Law

Polsinelli on

China has recently joined the list of countries that have adopted the world’s strictest data-privacy laws. Given China’s desirability as both a market for and a source of data, companies worldwide have started making early...more

McDermott Will & Emery

China’s Draft Cybersecurity Measures Suggest Increased Focus on Data Security

McDermott Will & Emery on

On 28 May 2019, the Cyberspace Administration of China (CAC) released the “Data Security Management Measures (Draft for Comments)” (Draft Measures) (unofficial English translation here), containing detailed rules to expand...more

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