News & Analysis as of

National Security Sensitive Personal Information Personal Data

Robinson+Cole Data Privacy + Security Insider

Clock Ticking: DOJ’s New Data Security Rule Requires Compliance by July 8

U.S. companies are running out of time to comply with a sweeping new Department of Justice (DOJ) rule that limits sharing sensitive personal data with certain foreign countries—including China, Russia, and Iran. With a hard...more

Jenner & Block

Client Alert: Myth Busters: Dispelling Common Misconceptions of the Department of Justice’s Data Security Program

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A month has passed since the Department of Justice (DOJ) National Security Division’s (NSD) issued its Final Rule prohibiting certain transactions involving US government data and Americans’ bulk sensitive personal data....more

Eversheds Sutherland (US) LLP

Navigating new compliance requirements for DOJ’s Bulk Data Rule

While the US federal government is largely scaling back its rulemaking and compliance efforts, one critical exception is where personal data and technology intersect with national security. Exemplifying this trend, on April...more

ArentFox Schiff

Navigating the DOJ’s New Data Transfer Rule: Implications and Compliance Requirements

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On January 8, the US Department of Justice (DOJ) issued a final rule under Executive Order 14117, which established the Rule Preventing Access to US Sensitive Personal Data and Government-Related Data by Countries of Concern...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

Kelley Drye & Warren LLP

The Bulk Data Access Rule: What Advertisers Need to Know

On April 11, the Department of Justice issued an extensive set of FAQs on its Bulk Data Access Rule and advised that it ​“will not prioritize civil enforcement actions against any person for violations” of the Rule through...more

The Volkov Law Group

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

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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

Womble Bond Dickinson

Navigating the New DOJ Data Security Program Compliance

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On January 8, 2025, the U.S. Department of Justice (“DOJ”) issued its final rule to implement Executive Order 14117 aimed at preventing access to Americans' bulk sensitive personal data and government-related data by...more

Dorsey & Whitney LLP

DOJ Limits Enforcement During First 90 Days of US-China Data Export Rules

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In a Press Release issued April 11, 2025, the U.S. Department of Justice (“DOJ”) indicated that it would prioritize “facilitating compliance” over civil enforcement actions for the first 90 days of its new US-China data...more

Goodwin

Life Sciences Companies Must Navigate the DOJ Data Rule

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Life sciences companies have long been outside the scope of US national security regulations and benefited from significant exemptions under US privacy laws. ...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

Ropes & Gray LLP

DOJ Bulk Data Final Rule Update

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Today, the Department of Justice’s (“DOJ”) Final Rule implementing former President Biden’s Executive Order 14117, “Preventing Access to Americans’ Bulk Sensitive Personal Data and United States Government-Related Data by...more

Miller Canfield

DOJ Rule Restricting Sensitive Data Transfers Takes Effect

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Today, April 8, 2025, the U.S. Department of Justice’s Final Rule restricting transfers of bulk sensitive personal data and U.S. government-related data becomes effective, implementing former President Biden’s Executive Order...more

Lathrop GPM

New DOJ Limits on Cross-Border Data Transfers Prompt Assessment by Businesses

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On April 8, the National Security Division of the U.S. Department of Justice’s (DOJ) new rule on cross-border data transfers takes effect. It restricts U.S. businesses from transferring certain bulk sensitive personal data to...more

Akin Gump Strauss Hauer & Feld LLP

Security Requirements and Compliance Obligations in DOJ's Final Rule on Data Transactions

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

Robinson+Cole Data Privacy + Security Insider

Privacy Tip #431 – DOGE Has Access to Our Personal Information: What You Need to Know

According to a highly critical article recently published by TechCrunch,  the Department of Government Efficiency (DOGE), President Trump’s advisory board headed by Elon Musk, has “taken control of top federal departments and...more

Dorsey & Whitney LLP

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

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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

Mayer Brown

Export of Sensitive Personal Data: US Department of Justice Issues Final Rule to Regulate

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On December 27, 2024, the Department of Justice (DOJ) released a Final Rule, Provisions Pertaining to Preventing Access to U.S. Sensitive Personal Data and Government-Related Data by Countries of Concern or Covered Persons....more

WilmerHale

DOJ Issues NPRM Regarding Sensitive Data Transfers

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With the publication of a recent Notice of Proposed Rulemaking (NPRM), the Department of Justice National Security Division will soon become an important new regulator of transactions involving the transfer of sensitive U.S....more

Mayer Brown

Department of Justice Issues Notice of Proposed Rulemaking to Regulate Export of Sensitive Personal Data

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On October 21, 2024, the Department of Justice (DOJ) released an unpublished Notice of Proposed Rulemaking (NPRM), Provisions Pertaining to Preventing Access to U.S. Sensitive Personal Data and Government-Related Data by...more

Morgan Lewis

Could Sensitive Personal Data Become Export Controlled?

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Five US senators recently introduced legislation that would amend US export control laws to protect sensitive personal data. The bipartisan bill, titled the Protecting Americans’ Data from Foreign Surveillance Act of 2022,...more

StoneTurn

CFIUS: Three Trends to Know

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Foreign direct investment regimes, including CFIUS, regularly review transactions to assess potential risks to national security. What should organizations know about key trends behind a potential CFIUS review?...more

Akin Gump Strauss Hauer & Feld LLP

Biden Administration Reviewing Comments on Interim Final ICTS Rule

Key Points - On January 19, 2021, the U.S. Commerce Department published an interim final rule (IFR) to implement Executive Order 13873 of May 15, 2019, on “Securing the Information and Communications Technology and...more

Orrick, Herrington & Sutcliffe LLP

New CFIUS Rules – Eight Key Points

The Committee on Foreign Investment in the United States ("CFIUS") issued final regulations on January 13, 2020 to comprehensively implement the Foreign Investment Risk Review Modernization Act of 2018 ("FIRRMA") (the...more

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