News & Analysis as of

National Security Export Controls Data Security

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

Orrick, Herrington & Sutcliffe LLP

DOJ implements its Data Security Program to protect users’ data

On April 11, the DOJ announced steps towards the implementation of a national security program aimed at protecting Americans’ sensitive data from China, Russia, Iran and other foreign adversaries. The Data Security Program,...more

The Volkov Law Group

DOJ Issues Data Security Program Requirements (Part I of II)

The Volkov Law Group on

Many “good government” initiatives continue to be enacted or implemented on Capitol Hill or in the Executive Branch — notwithstanding changes in political control. While working on Capitol Hill, the bulk of the legislative...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

Sheppard Mullin Richter & Hampton LLP

DOJ Announces 90-Day Grace Period for Companies to Comply with New Data Security Rules on Foreign Adversary Access to U.S....

The U.S. Department of Justice (DOJ)’s new data security rule went into effect April 8, 2025. The rule creates what are effectively export controls and requires companies to take measures to prevent U.S. sensitive personal...more

Mintz

Trump Administration Receives 8,755 Comments for AI Action Plan — AI: The Washington Report

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The Trump administration’s Office of Science and Technology Policy received 8,755 comments in response to its Request for Information for the development of its AI Action Plan implementing the Trump AI Executive Order issued...more

Blake, Cassels & Graydon LLP

Canada Revises its National Security Review Guidelines for Investments

Amidst unprecedented trade tensions with the United States, on March 5, 2025, the Government of Canada (Government) released updated Guidelines on the National Security Review of Investments (Guidelines) under the Investment...more

American Conference Institute (ACI)

[Event] 15th Forum on Global Encryption, AI, Cloud & Cyber Export Controls - March 26th - 27th, San Francisco, CA

As global trade policy evolves faster than ever, now is the time to connect with your peers, discover new strategies, and most importantly, hear from the regulatory agencies on the front lines of policy change. ACI’s 15th...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

Morrison & Foerster LLP

BIS Issues Interim Final Rule on Artificial Intelligence Diffusion as Biden Exits

On January 13, 2025, the Department of Commerce’s Bureau of Industry and Security (BIS) published an Interim Final Rule (IFR) that expands controls on advanced computing integrated circuits (ICs or chips) and model weights...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

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

Pillsbury - Global Trade & Sanctions Law

BIS Issues Interim Final Rule Establishing a Framework for Artificial Intelligence Diffusion

On January 13, 2025, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) issued an Interim Final Rule (IFR), establishing new export controls targeting advanced artificial intelligence (AI) chips and model...more

Mayer Brown

US Department of Commerce Issues Interim Final Rule Designed to Protect American AI

Mayer Brown on

On January 13, 2025, the US Department of Commerce’s Bureau of Industry and Security (BIS) published an Interim Final Rule (IFR) titled “Framework for Artificial Intelligence Diffusion.” The IFR builds on a long series of...more

Skadden, Arps, Slate, Meagher & Flom LLP

Political Changes Are Unlikely To Fundamentally Alter Key Sanctions

Key Points - - Political transitions in the West notwithstanding, we expect economic sanctions to remain a key response to geopolitical issues. - Current sanctions policy priorities are unlikely to shift markedly in...more

Torres Trade Law, PLLC

A Primer on the Committee on Foreign Investment in the United States (CFIUS)

The Committee on Foreign Investment in the United States (“CFIUS” or “the Committee) is an interagency body of the U.S. government that plays a critical role in safeguarding national security by reviewing foreign investments...more

Morrison & Foerster LLP

M&A in 2023 and Trends for 2024

M&A activity in 2023 was subdued, as dealmakers grappled with geopolitical tensions, inflation, rising interest rates, and increasing regulatory scrutiny, against a backdrop of general economic uncertainty. Challenges in the...more

King & Spalding

Protecting Americans’ Data from Foreign Surveillance Act

King & Spalding on

A bipartisan group of U.S. senators introduced legislation on June 23, 2022, to provide the federal government authority to limit or prevent the sale of Americans’ personal data to “high-risk” countries and malign foreign...more

American Conference Institute (ACI)

[Virtual Event] U.S. Export & Reexport Compliance For Canadian Operations - January 26th - 27th, 9:00 am - 5:00 pm EST

For a whole decade, ACI’s U.S. Export & Reexport Compliance for Canadian Operations conference continues to stand apart as the only practical, comprehensive event of its kind for the export compliance community in Canada. ...more

Jones Day

Jones Day Talks: Trump's Artificial Intelligence Initiative: Implications, Impact, and Industry Reactions

Jones Day on

President Trump's American AI Initiative is a far-reaching plan designed to ensure the United States remains a world leader in artificial intelligence research, development, and deployment. Jones Day's Emily Tait, Samir...more

Proskauer Rose LLP

Foreign Investment Review Under CFIUS Expands With New Legislation

Proskauer Rose LLP on

Pilot Program Mandatory Filing Requirement – Private Investment Fund Considerations - The potential for national security review of foreign investment in the U.S. has been around for 30 years since the 1988 enactment of...more

Jones Day

FIRRMA Broadens Scope of Foreign Investments Subject to CFIUS Review

Jones Day on

The Situation: The National Defense Authorization Act ("NDAA"), which contains the Foreign Investment Risk Review Modernization Act ("FIRRMA"), broadens the scope of foreign investments subject to scrutiny by the Committee on...more

Akin Gump Strauss Hauer & Feld LLP

The CFIUS Reform Legislation—FIRRMA—Will Become Law on August 13, 2018

CFIUS will continue to have broad jurisdiction to conduct national security reviews of foreign investments that could result in foreign control of a U.S. business. When regulations implementing FIRRMA become effective within...more

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