This article was originally published by IAPPĀ linked here. On 8 Jan., the U.S. Department of Justice published in the Federal Register its final rule on protecting Americans’ sensitive data from foreign adversaries. As a follow-up, on 11 April, the DOJ’s National Security Division took additional steps to implement the final rule. Specifically, the DOJ issued answers to more than 100 frequently asked questions, published a compliance guide, and issued a limited enforcement policy for the first 90 days of the final…
This article was originally published by IAPP linked here. The U.S. Department of Justiceās final rule on protecting Americansā sensitive data from foreign adversaries is now in effect. On 11 April, the DOJās National Security Division took further steps to implement the final rule and also issued a limited 90-day enforcement policy promising not to take certain enforcement actions against companies engaging in good faith compliance efforts until 8 July. The final rule represents a novel approach…
On April 11, 2025, the US Department of Justice National Security Division (āDOJā) took steps to implement its December 2024 Final Rule on Protecting Americansā Sensitive Data from Foreign Adversaries (āFinal Ruleā). Specifically, the DOJ issued answers to more than 100 Frequently Asked Questions (āFAQsā), published a Compliance Guide, and issued a Limited Enforcement Policy for the first 90 days of the Final Rule. This Baker McKenzie Client Alert outlines key points regarding the FAQs,…
On December 30, 2024, the US Department of Justice (āDOJā) issued a Final Rule intended to prevent certain countries from exploiting specific categories of sensitive personal data and government data. The Final Rule will become effective on April 8, 2025 without any further executive or regulatory action needed from the new Trump Administration. The Final Rule represents a novel approach to the national security concerns related to sensitive personal and government data that mixes elements…