News & Analysis as of

Department of Justice (DOJ) 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

Epstein Becker & Green

DOJ’s Final Rule on Bulk Data Transfers: A Road Map

To help prevent countries of concern or “covered persons” from accessing U.S. government-related data and Americans’ bulk sensitive personal data, the National Security Division (NSD) of the U.S. Department of Justice (DOJ)...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

Orrick, Herrington & Sutcliffe LLP

RegFi Episode 63: DOJ Issues Final Rule on International Data Transfers

Orrick Partners Matthew Coleman and Jeanine McGuinness join RegFi co-hosts Jerry Buckley and Sherry Safchuk to explore the implications of the Justice Department’s recent issuance of a final rule prohibiting and restricting...more

Gardner Law

New DOJ Rule Restricts Deidentified Data Transfer

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No Safe Harbor: New DOJ Data Export Rule Restricts Deidentified Data Transfer - This article outlines new requirements from the Department of Justice regarding “bulk sensitive data”, including de-identified, anonymized,...more

Skadden, Arps, Slate, Meagher & Flom LLP

Deadline Fast Approaching for Data Security Program Compliance

The Department of Justice (DOJ) implemented a new regulatory regime (Data Security Program) addressing access to, and transfer of, sensitive personal data to countries and persons of concern, including Russia, China and...more

Holland & Knight LLP

U.S. Health Data Affected by New National Security Restrictions on International Data Transfers

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Health Insurance Portability and Accountability Act (HIPAA)-covered entities and business associates should be familiar with restrictions on the use or disclosure of protected health information (PHI) under HIPAA rules....more

Orrick, Herrington & Sutcliffe LLP

UPDATE: DOJ Issues Bulk Sensitive Data Rule Guidance, Requirements Go into Effect: What Companies Need to Know

On April 11, 2025, the Department of Justice’s (DOJ) National Security Division (NSD) released an Implementation and Enforcement Policy, a Compliance Guide, and a list of over 100 Frequently Asked Questions (FAQs) to help...more

Bass, Berry & Sims PLC

DOJ Publishes Final Rule Restricting Bulk Cross-Border Data Transfers of Sensitive Data to Foreign Persons

On April 8, the U.S. Department of Justice’s (DOJ) Final Rule, codified at 28 CFR Part 202, (Final Rule), implementing President Biden’s Executive Order 14117 “Preventing Access to U.S. Sensitive Personal Data and...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

Venable LLP

DOJ Data Security Program Key Developments: A 90-Day "Good Faith" Extension, Compliance Guide, and Extensive FAQs

Venable LLP on

On April 11, the Department of Justice's National Security Division (NSD) published new guidance on recent measures to restrict the ability of adversarial foreign governments and other foreign entities of concern to access...more

Perkins Coie

DOJ’s Bulk Personal Data Rule Becomes Effective–Resources for Compliance

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The new Department of Justice (DOJ) rule governing international transfers of Americans’ information, codified at 28 C.F.R. Part 202, became effective on April 8, 2025....more

ArentFox Schiff

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

ArentFox Schiff on

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

Jackson Lewis P.C.

DOJ New Data Transfer Rule Impacts Hiring Practices, Business Operations, and Vendor Management: Time to Review Your Privacy +...

Jackson Lewis P.C. on

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

Womble Bond Dickinson on

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

Clark Hill PLC

DOJ implements new rule restricting bulk transfers of sensitive personal data

Clark Hill PLC on

On April 22, FTC Commissioner Melissa Holyoak delivered the opening keynote at the IAPP Global Summit, where she emphasized the importance of vigorously enforcing privacy laws while warning against stretching the FTC’s...more

WilmerHale

DOJ Issues Guidance for New Data Security Program

WilmerHale on

On April 8, the Department of Justice’s (“DOJ’s”) final rule on Preventing Access to US Sensitive Personal Data and Government-Related Data by Countries of Concern or Covered Persons (the “Rule”) formally took effect. ...more

Jenner & Block

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

Jenner & Block on

On April 8, 2025, the United States Department of Justice’s (DOJ) National Security Division’s (NSD) final rule (Final Rule) regulating certain sensitive US data transfers took effect. DOJ has made clear that it will take...more

BakerHostetler

DOJ Implements Bulk Personal Data Transfer Restrictions

BakerHostetler on

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

Paul Hastings LLP

Department of Justice Provides New Guidance on Bulk Sensitive Data Transfer Rules

Paul Hastings LLP on

The Department of Justice’s National Security Division (NSD) released several documents on April 11, 2025, to assist entities that must comply with the Final Rule regulating or prohibiting the transfer of bulk U.S. sensitive...more

DLA Piper

US: Department of Justice Issues Final Rule Restricting the Transfer of Sensitive Personal Data and United States...

DLA Piper on

On April, 8 2025, the Department of Justice’s final rule, implementing the Biden-era Executive Order 14117 restricting the transfer of Americans’ Sensitive Personal Data and United States Government-Related Data to countries...more

Dorsey & Whitney LLP

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

Dorsey & Whitney LLP on

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

Littler

DOJ Rule Implementing Executive Order 14117 Regulating Cross-Border Data Transfers Takes Effect

Littler on

DOJ rule to implement Executive Order 14117, which restricts the exchange of sensitive personal data with certain “countries of concern,” took effect April 8. The order, which was issued under the prior administration,...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

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