DOJ’s Final Rule on Bulk US Sensitive Data Transfers

2025 Enforcement Outlook | Compliance Strategies for the DOJ’s Final Rule on Bulk US Sensitive Data Transfers

Overview


The US Department of Justice’s (DOJ’s) final rule on bulk US sensitive data transfers aims to prevent or restrict the transfer of bulk US sensitive personal data to countries the US government deems high-risk. The rule, which took effect on April 8, 2025, introduces new compliance obligations and potential civil and criminal penalties for noncompliance, impacting data management and companies’ international operations.

In this webinar, members of McDermott’s cross-practice team provided a comprehensive overview of the DOJ’s final rule and its practical implications for businesses.

Discussion topics included:

  • Foundations of the final rule and its key provisions
  • Actionable guidance for effective implementation
  • Key considerations for contractual arrangements in light of the new rule
  • How the final rule ties to Chinese-related restrictions, including the Committee on Foreign Investment in the United States’ inbound investments and proposed rules to limit government contracts

McDermott’s Enforcement Outlook webinar series is designed to keep you up to date on the enforcement trends that might impact your organization’s compliance strategy. For more materials related to past episodes, visit our Enforcement Outlook Series hub.

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