News & Analysis as of

Data Privacy China

Dacheng

China Issues First Administrative Penalty for Unlawful Cross Border Transfer of Personal Information

Dacheng on

On September 9, 2025, China announced the landmark administrative penalty against Dior (Shanghai) over unlawful cross-border transfers of personal information, with the primary violation being the failure to satisfy the...more

Morgan Lewis

China’s New Standard on Sensitive Personal Information Goes Into Effect November 1

Morgan Lewis on

In a move to further bolster data privacy, China’s State Administration for Market Regulation and the Standardization Administration of China jointly issued a national standard, GB/T 45574-2025, Data Security Technology –...more

Ropes & Gray LLP

Reintroduction of the BIOSECURE Act: Potential Impact on the Biotechnology Industry

Ropes & Gray LLP on

The BIOSECURE Act (“the Act”), which received bipartisan support in both the U.S. House of Representatives and U.S. Senate in 2024 but was not ultimately passed into law, has re-emerged in this session of Congress, but with...more

Dickinson Wright

QuickHits: Executive Order 14117 Comes into Force: Key Considerations for Cross-Border Data Transfers

Dickinson Wright on

Welcome to QuickHits! A concise newsletter that covers current cases, recent hot topics, and/or pressing questions pertaining to the rapidly evolving U.S.-China relationship and related legal and commercial environments....more

Robinson+Cole Data Privacy + Security Insider

Android VPN Apps Linked to Chinese Co (Qihoo 360) Tied to PRC

Researchers at Arizona State University and Citizen Lab have discovered that three families of Android VPN applications, used by millions of people worldwide, are related and owned by companies or individuals located in...more

Dacheng

China Monthly Data Protection Update: August 2025

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This monthly report outlines key developments in China’s data protection sector for August. The following events merit special attention: CAC Summons NVIDIA Over Cybersecurity Concerns Related to H20 Chip: On July 31, CAC...more

Warner Norcross + Judd

Avoid the October Surprise: What You Need to Know About DOJ’s New Data Security Program

Warner Norcross + Judd on

The Department of Justice’s (“DOJ”) Data Security Program (“the Program”, 28 C.F.R. Part 202) went into effect on April 8 with a 90-day period of limited enforcement. With DOJ now expecting full compliance, with additional...more

Knobbe Martens

FDA Announces Review of New Clinical Trials That Export Americans’ Biological Samples to Hostile Countries

Knobbe Martens on

On June 18, 2025, the U.S. Food and Drug Administration (FDA) announced that it will review new clinical trials that involve sending biological samples to “hostile countries,” to prevent exploitation of Americans’ sensitive...more

DLA Piper

CHINA: Definition and Handling of Sensitive Personal Information Helpfully Clarified

DLA Piper on

It’s well-known that China’s data protection laws define sensitive personal information very differently to other jurisdictions. Instead of a closed list of data types, sensitive personal information in China has...more

Robinson+Cole Data Privacy + Security Insider

Kentucky AG Sues Temu for “Stealing Kentuckians’ Data”

Following in the footsteps of almost two dozen attorneys general in other states, Kentucky Attorney General Russell Coleman filed a lawsuit on July 17, 2025, against Chinese online shopping platform Temu, alleging that it...more

Sheppard Mullin Richter & Hampton LLP

China Initiates Mandatory Reporting Regime for Personal Information Protection Officers

On July 18, 2025, the Cyberspace Administration of China (the “CAC”) issued the Notice on Launching the Reporting Mechanism for Personal Information Protection Officers (the “Notice ”). This development marks a significant...more

Morrison & Foerster LLP

FTC Looks to Leverage PADFAA Enforcement to Help Limit Exposure of Consumer Data

In recent comments, Commissioner Holyoak signaled that the Federal Trade Commission will prioritize enforcement of the Protecting Americans’ Data from Foreign Adversaries Act (PADFAA), a law that empowers the FTC to police...more

Dacheng

China Monthly Data Protection Update: July 2025

Dacheng on

This monthly report outlines key developments in China’s data protection sector for July. The following events merit special attention: CAC Issues Third Edition of the Data Export Security Assessment Application Guide: On...more

DLA Piper

CHINA: DPOs Must Be Registered Before 29 August 2025

DLA Piper on

While appointing and registering a DPO has been mandatory in China for many years, a portal has now finally been established for organisations to register those DPOs with the China data protection authority. This resolves...more

McDonnell Boehnen Hulbert & Berghoff LLP

AI News Roundup – Nvidia wins approval to sell advanced AI chips in China, U.S. government expands AI usage, AI training dataset...

To help you stay on top of the latest news, our AI practice group has compiled a roundup of the developments we are following....more

Proskauer - Minding Your Business

DOJ Begins Enforcement of New Data Security Program

On July 9, 2025, the Department of Justice (“DOJ”) commenced enforcement of its new Data Security Program (“DSP”) to prevent foreign adversaries from accessing sensitive U.S. data. Created earlier this year, the program seeks...more

Jenner & Block

New Rules for Data Flows Take Effect: What You Need to Know

Jenner & Block on

On April 8, 2025, the US Department of Justice’s National Security Division’s final rule regulating sensitive data about US persons came into effect. DOJ also announced a 90-day grace period on enforcement. At a moment of...more

Orrick, Herrington & Sutcliffe LLP

DOJ begins enforcement of its Data Security Program

On July 8, the DOJ’s National Security Division (NSD) will begin enforcing its Data Security Program according to a notice from April titled “Data Security Program Implementation and Enforcement Policy” which outlined the...more

Morgan Lewis

DOJ's Data Security Program Enforcement in Full Swing: Key Considerations for Companies

Morgan Lewis on

The US Department of Justice’s (DOJ’s) final rule implementing Executive Order (EO) 14117, Preventing Access to Americans’ Bulk Sensitive Personal Data and United States Government-Related Data by Countries of Concern went...more

Dacheng

Cross-Border Data Processing under the "Offshore Model": China's Regulatory Approach in Comparative Context

Dacheng on

As the digital economy continues to thrive and remote work becomes increasingly mainstream, an “offshore model” of business operation has emerged. Under this model, companies may provide services to users in a given...more

Wiley Rein LLP

Update: Enforcement of DOJ Data Security Program Set to Begin July 9

Wiley Rein LLP on

The U.S. Department of Justice (DOJ) is set to enforce its sweeping new rule on certain U.S. data transactions with countries of concern and covered persons as of July 9, 2025. The new rule regarding “Preventing Access to...more

Orrick, Herrington & Sutcliffe LLP

5 Things In-House Counsel Must Know Before DOJ’s Bulk Transfer Rule Enforcement Begins

The Department of Justice’s (DOJ) 90-day grace period for compliance with the Data Security Program (DSP) ends on July 8, 2025, and enforcement is expected to begin. This regulatory regime was created for national security...more

Quarles & Brady LLP

China's Sweeping 2025 Anti-Unfair Competition Law Revision: Far-Reaching Impacts on Brand Protection, Data Governance, eCommerce,...

Quarles & Brady LLP on

On June 27, 2025, China’s National People’s Congress Standing Committee enacted a landmark revision to the Anti-Unfair Competition Law (AUCL), effective October 15, 2025. This sweeping update is the most significant since the...more

Katten Muchin Rosenman LLP

FDA Scrutinizes Clinical Trials Exporting U.S. Genetic Material

On June 18, 2025, the U.S. Food and Drug Administration (“FDA”) announced an immediate review of new clinical trials that export American citizens’ biological materials to countries of concern, such as China, for genetic...more

Cozen O'Connor

No Buyer’s Remorse for Nebraska AG Over Temu Data Use Lawsuit

Cozen O'Connor on

Nebraska AG Mike Hilgers sued PDD Holdings Inc. and WhaleCo Inc., d/b/a Temu, alleging that Temu’s shopping app operates as malware designed to gain unauthorized access to users’ data in violation of state consumer protection...more

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