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International Data Transfers Personal Data China

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

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

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

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

Baker Donelson

DOJ Final Rule Targets Cross-Border Data Transfers: Key Implications for U.S. and Foreign-Owned Companies Operating in the U.S.

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In the final days of the Biden administration the U.S. Department of Justice (DOJ) issued a sweeping set of regulations which are in effect as of yesterday, April 8, 2025. The regulations focus on cross-border data transfers...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

Miller Canfield

DOJ Rule Restricting Sensitive Data Transfers Takes Effect

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Today, April 8, 2025, the U.S. Department of Justice’s Final Rule restricting transfers of bulk sensitive personal data and U.S. government-related data becomes effective, implementing former President Biden’s Executive Order...more

Goodwin

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

Goodwin on

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

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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

Sheppard Mullin Richter & Hampton LLP

Draft Measures for Personal Information Protection Certification for Cross-Border Data Transfers Released for Public Comment

On January 3, 2025, the Cyberspace Administration of China (the “CAC”) released the Draft Measures for Personal Information Protection Certification for Cross-Border Data Transfers (the “Draft Measures”) for public comment....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

Dorsey & Whitney LLP

Justice Issues Final Rule Restricting Transfer of Personal U.S. Data to Countries of Concern, Effective in April 2025

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The U.S. Department of Justice (“DOJ”) published its final rule (“Final Rule”) on January 8, 2025, that will prohibit or restrict transfer of certain data of U.S. persons to countries of concern, including to China. The Final...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

Benesch

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

Benesch on

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

Dorsey & Whitney LLP

Justice Proposes to Restrict U.S. Personal Data to Countries of Concern, Including China

Dorsey & Whitney LLP on

The U.S. Department of Justice (“DOJ”) released a Notice of Proposed Rulemaking (“Proposed Rule”) on October 21 that would prohibit or restrict the transfer of certain data of U.S. persons to China and other countries of...more

Butler Snow LLP

Proposed Rule Published Restricting Data Sharing with China, Russia, Iran, North Korea, Cuba, and Venezuela

Butler Snow LLP on

The US Department of Justice issued a Notice of Proposed Rule Making (NPRM) October 21, 2024 that, if finalized, will prohibit or restrict a significant amount of international data sharing with countries of concern,...more

WilmerHale

DOJ Issues NPRM Regarding Sensitive Data Transfers

WilmerHale on

With the publication of a recent Notice of Proposed Rulemaking (NPRM), the Department of Justice National Security Division will soon become an important new regulator of transactions involving the transfer of sensitive U.S....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

DLA Piper

CHINA: Mandatory Data Protection Compliance (Self) Audits on Their Way

DLA Piper on

The Personal Information Protection Law (“PIPL“) requires a data controller to conduct compliance audits of its personal data processing activities on a regular basis (“Self-supervision Audits“). Apart from such...more

Venable LLP

Data Restrictions in the 21st Century Peace through Strength Act

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On April 20, 2024, the House of Representatives passed H.R.8038, the 21st Century Peace through Strength Act ("supplemental"), which includes a version of H.R.7520, the Protecting Americans' Data from Foreign Adversaries Act...more

Katten Muchin Rosenman LLP

The Cybersecurity Administration of China Issues Relaxed Rules for Cross-Border Data Transfers

On March 22, 2024, the Cybersecurity Administration of China (CAC), issued the long-awaited new Regulations on Promoting and Regulating Cross-Border Data Flows (the New Regulations) for compliance with China's Personal...more

K&L Gates LLP

Safe Harbors Part II - China's Safe Harbor Rules Lower the Barrier for Cross-Border Data Transfer

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In Part I of our alert about China’s new safe harbor rules, we discussed key developments between the draft Provisions on Regulating and Facilitating Cross-Border Data Flow (Chinese version only) and the Provisions on...more

Sheppard Mullin Richter & Hampton LLP

China Issues Regulations on Facilitating and Regulating Cross-Border Data Flow

On March 22, 2024, nearly six months after the release of the “draft Provisions on Regulating and Promoting Cross-border Data Transfer” (the “Draft Rules”), the Cybersecurity Administration of China (the “CAC”) formally...more

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