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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
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
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
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
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
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
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
China’s primary data regulator, the Cyberspace Administration of China (CAC), released two sets of Q&As with respect to exporting data from China, one in April and one in May. The questions were selected from those raised...more
This post is one in a series where we discuss the US Department of Justice’s (DOJ’s) bulk sensitive data rule (rule), which prohibits individuals or entities from certain foreign countries, including China, from accessing...more
On July 8, 2025, the Department of Justice (“DOJ”) is set to lift its self-imposed pause on enforcing certain violations of its Rule Preventing Access to US Sensitive Personal Data and Government-Related Data by Countries of...more
The State Administration for Market Regulation and the Standardization Administration of China have jointly issued a new national standard applicable to companies conducting business in China, GB/T 45574-2025, Data Security...more
China rolled out its “new,” streamlined cross-border data transfer (CBDT) regime on March 22, 2024, with the issuance by the Cyberspace Administration of China (CAC) of the Provisions on Facilitating and Regulating...more
The Interim AI Measures is China's first specific, administrative regulation on the management of generative AI services. Laws/Regulations/National Standards directly regulating AI (the "AI Regulations") The Cyberspace...more
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
On 14 February 2025, the Cyberspace Administration of China (“CAC”) issued the “Administrative Measures for Personal Information Protection Compliance Audits” (the "Measures"), which will take effect on 1 May 2025. The...more
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
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
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
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
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
The instant popularity of China’s DeepSeek-V3 generative artificial intelligence model underscores why companies should craft stronger GenAI policies that minimize the risks of employees exposing sensitive data, violating...more
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
Artificial intelligence (AI) has made enormous strides in recent years and has increasingly moved into the public consciousness. Explore Trendscape Our take on the interconnected global trends that are shaping the business...more
A coalition of 21 Republican AGs, led by Montana AG Austin Knudsen, is urging Congress to pass the No DeepSeek on Government Devices Act, which would prohibit downloading and using DeepSeek’s AI software on government...more
Recently, the Cyberspace Administration of China (CAC), which is the primary data regulator in China, published a newsletter about the government authorities’ enforcement of Apps and websites that violated personal data...more