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Data Security China International Data Transfers

Wiley Rein LLP

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

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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

McDermott Will & Emery

New US Data Security Program limits sensitive data transfers

The United States Data Security Program (DSP) represents a significant regulatory undertaking by the US government to control the flow of bulk sensitive data to specific foreign countries, for national security purposes....more

Loeb & Loeb LLP

China’s CAC Answers Questions on Cross-Border Data Transfer in April and May Guidance

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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

Morrison & Foerster LLP

China’s New CBDT Regime: One Year On

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

Dacheng

China Monthly Data Protection Update: May 2025

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This monthly report outlines key developments in China’s data protection sector for May. The following events merit special attention...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

Womble Bond Dickinson

DOJ’s Data Security Program Final Rules Effective - Implications for Telecom Providers

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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 countries...more

DLA Piper

China: CAC Publishes Official Q&As for Cross-Border Data Transfer Regulation

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The Cyberspace Administration of China (CAC) released an important Q&A on cross-border data transfer requirements and policies in early April, providing clarification on a number of issues of concern to companies in China....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

Snell & Wilmer

Restricting Bulk Data Transfers: Insights into the Final Rule

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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

Dacheng

A Practical Review of China's Restrictions on Cross-Border Transfer of Personal Information: Developments and Framework

Dacheng on

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

Goodwin

DOJ’s Data Export Rule Is In Force April 8: What You Need to Do

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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

Lathrop GPM

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

Lathrop GPM on

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

Dacheng

China Monthly Data Protection Update: March 2025

Dacheng on

This monthly report outlines key developments in China’s data protection sector for March. The following events merit special attention...more

Troutman Pepper Locke

Do You Know Where Your Data Is Going? On April 8, New National Security Rules Take Effect

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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

Orrick, Herrington & Sutcliffe LLP

US Data Localization Law Coming Soon: DOJ Issues Final Rule on Certain Data Transfers to “Countries of Concern”

The Department of Justice has finalized prohibitions and restrictions on cross-border transfers of certain data to China and other “Countries of Concern” (as defined below). It seeks to address what is, in the U.S....more

DLA Piper

CHINA: Draft Regulation on Certification for Cross-Border Data Transfers Published

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On 3 January 2025, the Cyberspace Administration of China (“CAC“) released for public consultation the draft Measures for Certification of Personal Information Protection for Cross-Border Transfer of Personal Information...more

Mayer Brown

Guangzhou Internet Court issues the first decision on cross-border transfer of personal data under PIPL

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The Guangzhou Internet Court (the “Court”) recently issued its first judgment involving the cross-border transfer of personal data under the Personal Information Protection Law (“PIPL”).1 An international hotel group was...more

Mayer Brown

PRC Network Data Security Management Regulations

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On 30 September 2024, the State Council of the People's Republic of China published the Network Data Security Management Regulations (the “Regulations”).1 These Regulations finalise the Draft Regulations released for public...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

DOJ Proposes Rules Limiting Transfer of Sensitive Data to Countries and Individuals

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Pursuant to President Biden’s March Executive Order, the DOJ has proposed new rules limiting the transfer of certain categories of data to “countries of concern” or “covered persons”....more

Morgan Lewis

Chinese Court Concluded Landmark Case on Cross-Border Transfer of Personal Information

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The Guangzhou Internet Court released the first ruling interpreting the requirements for cross-border transfer of personal information under the Personal Information Protection Law (PIPL). This case has significant...more

WilmerHale

China Finalizes the Network Data Security Management Regulations and Issues the First Free Trade Zone Data Export Negative List

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On September 24, 2024, the State Council released the Regulations on the Management of Network Data Security (《网络数据安全管理条例》) (“Regulations”). The Regulations focus on prominent issues related to Personal Information (PI),...more

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