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National Security Personal Data

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

Jenner & Block

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

Jenner & Block on

On April 8, 2025, the US Department of Justice’s National Security Division’s final rule regulating sensitive data about US persons came into effect. DOJ also announced a 90-day grace period on enforcement. At a moment of...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

Bodman on

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

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

Katten Muchin Rosenman LLP

FDA Scrutinizes Clinical Trials Exporting U.S. Genetic Material

On June 18, 2025, the U.S. Food and Drug Administration (“FDA”) announced an immediate review of new clinical trials that export American citizens’ biological materials to countries of concern, such as China, for genetic...more

Alston & Bird

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

Alston & Bird on

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

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

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

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

Orrick, Herrington & Sutcliffe LLP

Payments industry associations argue against remittance transfer tax proposal

On May 28, the Senate Committee on Finance received a joint letter from several payments industry associations urging lawmakers to reject a proposed 3.5 percent tax on remittance transfers, which includes any transfer...more

Baker Donelson

DOJ Final Rule Casts Wider Net: Common Business Data May Now Trigger National Security Scrutiny

Baker Donelson on

If you thought your company's collection of email address, IP address, zip code, birth date, or cookie data was too mundane to catch the federal government's attention – think again. Effective April 8, 2025, a new DOJ final...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

Wyrick Robbins Yates & Ponton LLP

The Justice Department’s New Rule on Access to U.S. Sensitive Personal Data and Government-Related Data by Countries of Concern or...

On April 8, 2025, the Department of Justice’s new rule on Access to U.S. Sensitive Personal Data and Government-Related Data by Countries of Concern or Covered Persons took effect. The rule, referred to by DOJ as the Data...more

Jenner & Block

Client Alert: Myth Busters: Dispelling Common Misconceptions of the Department of Justice’s Data Security Program

Jenner & Block on

A month has passed since the Department of Justice (DOJ) National Security Division’s (NSD) issued its Final Rule prohibiting certain transactions involving US government data and Americans’ bulk sensitive personal data....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

Porter Hedges LLP on

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

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

Baker Donelson

DOJ Final Rule Applies to Anonymized, Pseudonymized, and De-Identified Data: What Data Licensors Need to Know

Baker Donelson on

What's Changed? The U.S. Department of Justice (DOJ) published a Data Security Program (DSP), pursuant to a final rule (Final Rule), which became effective on April 8, 2025....more

Seward & Kissel LLP

Not the Rite Stuff, Private Eyes, and Inquiring Minds

Seward & Kissel LLP on

Rite Aid bankruptcy update: report says pharmacy chain may be facing insolvency as businesses close | Fast Company - Having previously filed for bankruptcy in 2023, Rite Aid is now preparing to file a second bankruptcy...more

Baker Donelson

DOJ Issues Additional Guidance and Clarification on the Bulk Data Transfer Rule: What U.S. Businesses Need to Know

Baker Donelson on

On April 11, 2025, the Department of Justice's National Security Division (NSD) issued additional guidance to assist U.S. organizations in understanding and complying with the Data Security Program (DSP). As discussed in our...more

Kelley Drye & Warren LLP

The Bulk Data Access Rule: What Advertisers Need to Know

On April 11, the Department of Justice issued an extensive set of FAQs on its Bulk Data Access Rule and advised that it ​“will not prioritize civil enforcement actions against any person for violations” of the Rule through...more

DLA Piper

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

DLA Piper on

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

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