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International Data Transfers Regulatory Requirements Department of Justice (DOJ)

Holland & Knight LLP

U.S. Health Data Affected by New National Security Restrictions on International Data Transfers

Holland & Knight LLP on

Health Insurance Portability and Accountability Act (HIPAA)-covered entities and business associates should be familiar with restrictions on the use or disclosure of protected health information (PHI) under HIPAA rules....more

Orrick, Herrington & Sutcliffe LLP

UPDATE: DOJ Issues Bulk Sensitive Data Rule Guidance, Requirements Go into Effect: What Companies Need to Know

On April 11, 2025, the Department of Justice’s (DOJ) National Security Division (NSD) released an Implementation and Enforcement Policy, a Compliance Guide, and a list of over 100 Frequently Asked Questions (FAQs) to help...more

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

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

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

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.

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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

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

Venable LLP

A Brave New World: Four Considerations When Building a Bulk Data Rule Compliance Program

Venable LLP on

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

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

WilmerHale

DOJ Finalizes Rule Regarding Sensitive Data Transfers

WilmerHale on

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

Venable LLP on

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

Jones Day

Justice Department Issues Final Rule on Bulk Transfers of Sensitive Personal Data to Certain Countries

Jones Day on

The final rule establishes prohibitions and restrictions on the transfer of certain data due to national security risks from specified countries of concern....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

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

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

Ropes & Gray LLP on

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

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

Benesch

United States Looks Towards its First Cross-Border Data Transfer Regime with New Executive Order

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President Biden issued an Executive Order last month calling on the DOJ and relevant government agencies to tighten regulations on bulk data transfers to “countries of concern.” In late February, President Biden issued...more

Mayer Brown

President Biden Issues Executive Order Empowering DOJ to Regulate the Export of Sensitive Personal Data

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On February 28, 2024, President Joe Biden issued Executive Order (“EO”) 14117, empowering the Department of Justice (DOJ) to regulate the export of certain consumer data, in order to prevent certain countries’ governments...more

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