Navigating the DOJ final rule on bulk sensitive personal data: What does it mean for your business?

By Sameer Ansari 

Managing Director

Multinational organizations must now comply with a sweeping new U.S. Department of Justice rule that restricts the transfer of bulk sensitive personal data to foreign adversaries. The rule, established under Executive Order 14117, went into effect earlier this month and introduces prohibitions and controls on data transactions involving countries of concern such as China, Russia, Iran, North Korea, Cuba and Venezuela.

Unlike traditional data privacy laws, this rule is rooted in national security and emphasizes the risk of seemingly lawful data transfers being exploited for espionage or coercion. It applies even to anonymized or encrypted data if re-identification is reasonably possible. Organizations will need to rethink compliance strategies, especially around data discovery, inventory management and cross-border data flows.

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