News & Analysis as of

International Data Transfers Enforcement Actions

Constangy, Brooks, Smith & Prophete, LLP

What the Sensitive Data Rule means for “bulk data” and National Security compliance

As of July 9, the U.S. Department of Justice has begun full enforcement of a sweeping new data regulation known as the Sensitive Data Rule, or “SDR.” Implemented under President Biden’s Executive Order 14117, the SDR marks a...more

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

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

Katten Muchin Rosenman LLP

Privacy, Data and Cybersecurity Quick Clicks | Issue 30

Katten's Privacy, Data and Cybersecurity Quick Clicks is a monthly newsletter highlighting the latest news and legal developments involving privacy, data and cybersecurity issues across the globe....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

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

Dacheng

China’s First Judicial Decision on Cross-Border Personal Information Transfers: Clarification on Data Localization Requirement

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In August 2024, China Judgements Online published a ruling issued by the Guangzhou Internet Court on September 8, 2023, in a case widely regarded as China’s first judicial decision addressing cross-border personal information...more

Constangy, Brooks, Smith & Prophete, LLP

Constangy Clips Ep. 10 - 3 Ways the GDPR Is Evolving with Today’s Tech Landscape

In recognition of the GDPR's 7th anniversary on May 25, 2025, Constangy Cyber Team member Matthew Basilotto explores how the European Union’s General Data Protection Regulation (GDPR) continues to adapt in the face of...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

Maynard Nexsen

Irish Data Protection Commission Fines TikTok Over EEA Data Transfers to China

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On May 2, 2025, the Irish Data Protection Commission (“DPC”) issued a decision, as lead supervisory authority, finding that TikTok infringed the GDPR regarding (a) its cross-border transfers of EEA User Data to China, and (b)...more

Blake, Cassels & Graydon LLP

Gouvernail des données de Blakes : mai 2025

Bienvenue à la toute première édition de l’infolettre Gouvernail des données de Blakes, une publication du groupe Protection de la vie privée et des données de Blakes. Cette infolettre a pour but d’effectuer un survol des...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

WilmerHale

DOJ Issues Guidance for New Data Security Program

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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

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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

Paul Hastings LLP

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

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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...

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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

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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

Littler

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

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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

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

American Conference Institute (ACI)

[Event] 15th Forum on Global Encryption, AI, Cloud & Cyber Export Controls - March 26th - 27th, San Francisco, CA

As global trade policy evolves faster than ever, now is the time to connect with your peers, discover new strategies, and most importantly, hear from the regulatory agencies on the front lines of policy change. ACI’s 15th...more

Smith Anderson

GDPR Enforcement is Alive and Well - Key Considerations in 2025

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As 2025 progresses, one thing is clear—GDPR enforcement is not slowing down. In fact, regulators across Europe are intensifying their scrutiny, handing out significant fines and even warning executives of potential personal...more

BakerHostetler

Year-End Review - Data Privacy Insights To Take into 2025

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In 2024, our team at BakerHostetler worked with hundreds of clients on a wide range of challenging privacy and data protection compliance issues. As the year ends, we are once again highlighting some key areas that warrant...more

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