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National Security Personal Data Regulatory Requirements

Jenner & Block

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

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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

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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

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

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

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

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

Jenner & Block

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

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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

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

Baker Donelson

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

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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

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

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

The Volkov Law Group

DOJ Issues Data Security Program Requirements (Part I of II)

The Volkov Law Group on

Many “good government” initiatives continue to be enacted or implemented on Capitol Hill or in the Executive Branch — notwithstanding changes in political control. While working on Capitol Hill, the bulk of the legislative...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

Goodwin

Life Sciences Companies Must Navigate the DOJ Data Rule

Goodwin on

Life sciences companies have long been outside the scope of US national security regulations and benefited from significant exemptions under US privacy laws. ...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.

Baker Donelson on

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

Ropes & Gray LLP

DOJ Bulk Data Final Rule Update

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Today, the Department of Justice’s (“DOJ”) Final Rule implementing former President Biden’s Executive Order 14117, “Preventing Access to Americans’ Bulk Sensitive Personal Data and United States Government-Related Data by...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

McDermott Will & Emery

Special Report - Navigating the DOJ’s Final Rule on Preventing Access to Bulk US Sensitive Data by Countries of Concern

The US Department of Justice’s (DOJ’s) Final Rule on preventing access to US sensitive personal data, published in the Federal Register on January 8, 2025, will prohibit or significantly restrict the transfer of or other...more

Latham & Watkins LLP

Kingdom of Saudi Arabia Issues New Data Transfer Risk Assessment Guidelines

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The guidelines specify the requirements for data controllers to conduct risk assessments related to the transfer or disclosure of personal data outside the Kingdom. ...more

Paul Hastings LLP

DOJ and CISA Issue Proposed Rules Regulating Export of Bulk Sensitive Data

Paul Hastings LLP on

The Department of Justice (DOJ) released a Final Rule restricting certain transfers of Americans’ sensitive personal data to identified countries of concern or covered individuals. The Final Rule continues to assert the DOJ...more

Sheppard Mullin Richter & Hampton LLP

Data, Deals, and Diplomacy, Part III: DOJ Issues National Security Final Rule with New Data Compliance Obligations for...

On January 8, 2025, the Department of Justice (“DOJ”) published its final rule addressing Executive Order (E.O.) 14117, “Preventing Access to Americans’ Bulk Sensitive Personal Data and United States Government-Related Data...more

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