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 or Covered Persons (the Rule).
Read Executive Order 14117 here . The Rule , which took effect on April 8, establishes export-like restrictions and prohibitions on transferring specific types of “bulk U.S. sensitive personal data” and certain specified “government-related data” (including of current or recent US government employees and sensitive government location data) to designated “countries of concern,” including China (with Hong Kong and Macau), Iran, North Korea, Cuba, Venezuela, and Russia, as well as transactions involving “covered persons,” which includes entities that are established under the laws of by a country of concern and their employees. The Rule established high civil penalties and allows for criminal enforcement. However, on April 11, DOJ paused civil enforcement until July 8 on the express condition of “good-faith” efforts to comply, or to come into compliance with the Rule, in the meantime. Criminal enforcement was not paused. Who and What Is Covered? The Rule delineates four main categor...