Log in or register
Share on LinkedInShare on LinkedIn

ARTICLE · 20 OCTOBER 2025

Market Intelligence Thought Leadership Award Winner

Update On China Data Privacy Enforcement: Recent Cross-Border Data Transfer Cases

Arnold & Porter
Arnold & Porter
Contributor
Arnold & Porter

Arnold & Porter

With over 1,000 lawyers across 16 offices worldwide, Arnold & Porter is renowned for its...

View firm profile
Explore more from Arnold & Porter

In September, Chinese regulators published two case studies discussing their enforcement of cross-border data transfer regulations.

ChinaPrivacy
John Tan
John Tan
Siyi Gu
Siyi Gu
Author LinkedIn connections

In September, Chinese regulators published two case studies discussing their enforcement of cross-border data transfer regulations. These cases provide insight into how China's regulatory scheme is implemented and may signal an increasing level of enforcement.

Shanghai Case Study

On September 9, 2025, China's National Network and Information Security Report Center (the Center, 国家网络与信息安全信息通报中心) announced that it had closed an administrative investigation and taken legal action against the Shanghai subsidiary of a European luxury brand (Company A) for violating China's Personal Information Protection Law (PIPL, 个人信息保护法) by illegally transferring personal information overseas.

We operate a free-to-view policy, asking only that you register in order to read all of our content. Please login or register to view the rest of this article.

Register for freeORLog in

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

View source

Related Articles

Legal Intelligence Newsletters: sign up for the latest legal and regulatory news on your chosen topics

Read more about

Related Comparative Guides

See more popular content from

Article

China Cross-border Data Transfer: Enforcement Has Arrived

China's cross-border data transfer regime has moved from paper framework to active enforcement in 2026, with regulators issuing significant fines and new rules for both small and large data processors. The three-pathway framework of CAC security assessment, Standard Contract filing, and personal information protection certification is now fully operational, creating real compliance obligations for any business moving personal data out of China.
ChinaPrivacy
BUREN
BUREN
Article

中企出海法律合规系列——数据泄露应对全流程指南

2022年，一场震惊全球的数据泄露事件将某知名国际网约车公司推上风口浪尖。黑客通过社交工程手段攻破其第三方供应商员工的VPN权限，进而入侵多个内部系统，导致大量员工和司机的姓名、邮箱、位置信息、账户内容等个人数据遭到外泄。事件发生后，美国联邦贸易委员会（FTC）率先发起调查&#
ChinaPrivacy
AnJie Broad Law Firm
AnJie Broad Law Firm
Article

Root Causes Updates And Insights On Quality And Inspections

This issue covers U.S. Food and Drug Administration (FDA), Drug Enforcement Administration (DEA), and U.S. Health and Human Services (HHS) developments spanning inspections, enforcement, transparency, and emerging product categories. FDA’s drug center and inspections office have updated their framework for coordinating facility evaluations and inspections (ConOps 2.0), and FDA has changed how it processes post-approval facility withdrawals for New Drug Applications (NDAs) and Abbreviated New Drug Applications (ANDAs).
United StatesFood, Drugs, Healthcare, Life Sciences
Arnold & Porter
Arnold & Porter
Article

The Chemical Compound — Q3 2026

This quarterly newsletter examines critical developments in chemical regulatory law, covering litigation outcomes that reshape EPA's authority under TSCA, landmark Supreme Court decisions on pesticide labeling preemption, and emerging state and international frameworks governing PFAS and other chemicals of concern. The edition analyzes how recent Fifth Circuit rulings on methylene chloride regulations may fundamentally alter EPA's approach to risk evaluations and management rules across its entire existing
United StatesEnvironment
Arnold & Porter
Arnold & Porter
Article

Pseudonymised, Not Anonymous: What The Italian Garante’s €7 Million IQVIA Fine Means For Health Data

The Italian data protection authority fined IQVIA Solutions Italy €7 million for treating patient records as anonymous when they were actually pseudonymised personal data subject to GDPR. This decision demonstrates regulators' strict interpretation of what constitutes personal data, even as the EU considers narrowing this definition through the Digital Omnibus reforms.
GlobalPrivacy
Arnold & Porter
Arnold & Porter
Article

FDA Issues Prescription Drug Use-Related Software Guidance After A Several-Year Delay

The FDA has finalized guidance on Prescription Drug Use-Related Software (PDURS), establishing how drug labeling authorities apply to software disseminated by pharmaceutical sponsors. This regulatory framework distinguishes between software essential to safe drug use and promotional applications, while clarifying submission requirements and clinical evidence standards for including software functions in FDA-approved prescribing information.
United StatesFood, Drugs, Healthcare, Life Sciences
Arnold & Porter
Arnold & Porter
Article

Generative AI Is Reshaping The Defense Of Complex Litigation

Generative AI is transforming litigation defense by enabling in-house legal teams to manage costs and complexity more effectively across the entire case lifecycle. From early research and drafting through expert witness strategy and trial preparation, AI tools are helping defense teams work faster and more consistently. How are these technologies reshaping the way sophisticated counsel approaches multidistrict litigation, mass torts, and large-scale document management?
United StatesMedia, Telecoms, IT, Entertainment
Arnold & Porter
Arnold & Porter
Article

The FCC’s Next Move On Supply Chain Security: What Manufacturers Need To Know

The Federal Communications Commission has proposed sweeping changes to its equipment authorization program that would reorganize security restrictions around where devices are manufactured rather than who makes them. These new measures could fundamentally reshape how communications equipment—from smartphones to data center hardware—enters the U.S. market, with significant implications for manufacturers relying on foreign production.
United StatesGovernment, Public Sector
Arnold & Porter
Arnold & Porter
Article

FTC Issues Rigorous Requirements On Using AI-Assisted Review Or Technology-Assisted Review To Respond To Investigational Subpoenas

The Federal Trade Commission has introduced stringent new requirements for parties using technology-assisted review or artificial intelligence in document production during investigations, mandating extensive upfront disclosures, prescriptive performance metrics, and validation processes. These requirements represent a significant departure from previous FTC practice and may discourage parties from using AI or TAR due to increased complexity and agency oversight. Parties now face critical decisions about wh
United StatesLitigation, Mediation & Arbitration
Arnold & Porter
Arnold & Porter
Article

Before The FCA: CMS And HHS Leaders Discuss Administrative Tools Leading Healthcare Fraud Enforcement

Federal healthcare fraud enforcement leaders reveal a strategic shift at CMS and HHS-OIG, where administrative sanctions—including enrollment moratoria, revocations, and exclusions—now serve as the first line of defense against fraud, often preceding False Claims Act litigation. The panel discussion at AHLA's Fraud and Compliance Forum outlined how agencies are leveraging data analytics, financial crimes intelligence, and cross-program coordination to identify and shut down fraudulent providers
United StatesFood, Drugs, Healthcare, Life Sciences
Arnold & Porter
Arnold & Porter