News & Analysis as of

National Security Data Privacy Enforcement Actions

Cohen & Gresser LLP

Evading DOJ Crosshairs As Data Security Open Season Starts

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The U.S. Department of Justice has added a new weapon to its enforcement arsenal, aimed at enhancing its ability to prevent foreign adversaries from accessing and exploiting government related data and sensitive personal data...more

Morrison & Foerster LLP

FTC Looks to Leverage PADFAA Enforcement to Help Limit Exposure of Consumer Data

In recent comments, Commissioner Holyoak signaled that the Federal Trade Commission will prioritize enforcement of the Protecting Americans’ Data from Foreign Adversaries Act (PADFAA), a law that empowers the FTC to police...more

Proskauer - Minding Your Business

DOJ Begins Enforcement of New Data Security Program

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

McDonnell Boehnen Hulbert & Berghoff LLP

AI News Roundup – Impostor uses AI to imitate U.S. Secretary of State, EU unveils code of practice for AI regulations, AI-powered...

To help you stay on top of the latest news, our AI practice group has compiled a roundup of the developments we are following....more

Orrick, Herrington & Sutcliffe LLP

DOJ begins enforcement of its Data Security Program

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

Morgan Lewis

DOJ's Data Security Program Enforcement in Full Swing: Key Considerations for Companies

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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

Bodman

DOJ Data Security Program – Another Privacy and Security Law that Impacts the Health Care Industry

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The Department of Justice (“DOJ”) implemented the Data Security Program (“DSP”) intending to prevent access to Americans’ bulk sensitive personal data and government-related data by Countries of Concern. The DSP is aimed at...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

Alston & Bird

Are You Ready for the Department of Justice’s Bulk Data Transfer Rule?

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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

Foley Hoag LLP - Security, Privacy and the...

DOJ’s “Bulk Sensitive Data Rule” is in Effect, and May Require Significant Compliance Obligations as Enforcement is Set to Begin

Pursuant to a newly effective U.S. Department of Justice (DOJ) regulation, the transfer and storage of certain sensitive U.S. government and personal data may be prohibited or restricted, depending on the intended recipient,...more

Hinshaw & Culbertson - Privacy, Cyber & AI...

AI Moratorium, Bulk Data Controls, and Enforcement Trends

To help our clients and readers sort through the volume of privacy, cyber, and AI news, we are switching Privacy, Cyber, & AI Decoded to a summary format. In this first edition, we look at a proposed 10-year moratorium on...more

Robinson+Cole Data Privacy + Security Insider

Clock Ticking: DOJ’s New Data Security Rule Requires Compliance by July 8

U.S. companies are running out of time to comply with a sweeping new Department of Justice (DOJ) rule that limits sharing sensitive personal data with certain foreign countries—including China, Russia, and Iran. With a hard...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

Eversheds Sutherland (US) LLP

Navigating new compliance requirements for DOJ’s Bulk Data Rule

While the US federal government is largely scaling back its rulemaking and compliance efforts, one critical exception is where personal data and technology intersect with national security. Exemplifying this trend, on April...more

Porter Hedges LLP

DOJ Issues Data Security Program Compliance Guide

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On April 11, 2025, the U.S. Department of Justice’s National Security Division (NSD) issued a Compliance Guide to provide additional information to assist companies and individuals in complying with the NSD’s Data Security...more

The Volkov Law Group

Episode 366 -- DOJ Issues Data Security Program Requirements

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Could your routine data transfers now violate federal law? The DOJ’s new Data Security Program (DSP) targets the flow of U.S. sensitive personal and government data to foreign adversaries — and the clock is ticking. In this...more

Pillsbury Winthrop Shaw Pittman LLP

DOJ Releases Its Data Security Program Compliance Guide

The guide outlines the requirements of a newly implemented Data Security Program designed to prevent China, Russia and other foreign adversaries designated by the U.S. Department of Justice from accessing American’s sensitive...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

Faegre Drinker Biddle & Reath LLP

DOJ Releases New Key Guidance on Its Data Security Program (DSP)

On April 11, 2025, the National Security Division (NSD) of the Department of Justice issued a press release (Press Release) that outlines its approach to implementing and enforcing the DOJ’s recent final rule on “Preventing...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

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