News & Analysis as of

International Data Transfers

Clark Hill PLC

DOJ implements new rule restricting bulk transfers of sensitive personal data

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On April 22, FTC Commissioner Melissa Holyoak delivered the opening keynote at the IAPP Global Summit, where she emphasized the importance of vigorously enforcing privacy laws while warning against stretching the FTC’s...more

Amundsen Davis LLC

Is My U.S.-Based Company Subject to the GDPR? Clearing Up European Data Privacy Law Misinformation

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If you are a compliance professional for a U.S.-based company, you have probably been told at some point that you have to worry about the General Data Protection Regulation (GDPR). Have you encountered one of these...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

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

Latham & Watkins LLP

Preparing for the European Health Data Space - Opportunities and Challenges for Europe’s Digital Future

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The EU regulation designed to facilitate secondary use of clinical data for research brings benefits for health research, but also poses challenges for companies....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

BakerHostetler

DOJ Implements Bulk Personal Data Transfer Restrictions

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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

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

Snell & Wilmer

Restricting Bulk Data Transfers: Insights into the Final Rule

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A new U.S. federal rule restricts bulk sharing of sensitive personal information and governmental information with certain countries, for some key industries. In December 2024, the Department of Justice issued a comprehensive...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

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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

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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

Ogletree, Deakins, Nash, Smoak & Stewart,...

Data in the Balance: Political Influence on EU-U.S. Data Transfers

In politically uncertain times, is your organisation’s data transfer compliance unquestionable? The EU-U.S. Data Privacy Framework (DPF) serves as a useful mechanism for transatlantic data transfers, and it can assist...more

Hogan Lovells

Latombe Case: First hearing for annulment of the EU-U.S. Data Privacy Framework

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On April 1st, 2025, the General Court of the European Union held its first hearing on the request initiated by member of French parliament Philippe Latombe for annulment of the EU-U.S. Data Privacy Framework (“DPF”) further...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

Morgan Lewis

Key Considerations for Foreign Clinical Trials When Looking Abroad for Product Development

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With the continuing cuts to US Food and Drug Administration (FDA) staffing, the pharmaceutical and biotechnology industries are communicating increasing concern about potential product development impacts. While these cuts...more

Dacheng

China Monthly Data Protection Update: March 2025

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This monthly report outlines key developments in China’s data protection sector for March. The following events merit special attention...more

Hogan Lovells

Streamlined BCR approval: Understanding the EDPB's updated procedure

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On 19 March 2025, the European Data Protection Board published an updated procedure for co-operation between EU data protection supervisory authorities approving GDPR Binding Corporate Rules for intra-group transfers of EU...more

White & Case LLP

Mexico Enacts New Data Protection Regime

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On March 20, 2025, the evening edition of the Federal Official Gazette published a decree (the "Decree") enacting the General Law on Transparency and Access to Public Information ("LGTAIP"), the General Law on the Protection...more

Alston & Bird

European Commission Moves to Extend Free Flows of Personal Data to the UK

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On March 18, 2025, the European Commission proposed to extend its adequacy decision in favor of the United Kingdom (‘UK’) for an additional six-month period. This would allow free flows of personal data from the EU to the UK...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

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