Log in or register
Share on LinkedInShare on LinkedIn

ARTICLE · 15 JANUARY 2025

Access Restricted: DOJ Prohibits Or Restricts Data Sharing With China, Russia, And Other Specified Countries

Goodwin Procter LLP
Explore more from Goodwin Procter LLP

On December 27, 2024, the US Department of Justice (DOJ) issued a final rule establishing a new national security program to prevent access to Americans' bulk sensitive personal data and

GlobalInternational Law
Richard Matheny, III
Richard Matheny, III
Jacob R. Osborn
Jacob R. Osborn
Justin C. Pierce
Justin C. Pierce
Peter M. Marta
Peter M. Marta
Omer Tene
Omer Tene
Carrie Miller
Carrie Miller
Jason Wilcox
Jason Wilcox
Gozde Guckaya
Gozde Guckaya
Justin Shields
Justin Shields
+1 more

On December 27, 2024, the US Department of Justice (DOJ) issued a final rule establishing a new national security program to prevent access to Americans' bulk sensitive personal data and government-related data by China (including Hong Kong and Macau), Russia, Venezuela, and other countries of concern. The rule implements President Biden's February 28, 2024 Executive Order 14117 and addresses public comments received in response to the DOJ's March 5, 2024 Advance Notice of Proposed Rulemaking and October 29, 2024 Notice of Proposed Rulemaking.

The final rule restricts — and in some instances prohibits — US persons from engaging in certain types of data brokerage, vendor agreements, employment agreements, and investment agreements with six "countries of concern" and "covered persons" related to those countries. Similar to the Outbound Investment Security Program, which took effect on January 2, 2025, the rule is designed to fill a perceived gap in US national

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.

Related Articles

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

Read more about

See more popular content from

Article

U.S.-China Trade Truce Extended Two Months: BIS Affiliates Rule Suspension Follows

The U.S.-China trade truce has been extended through January 10, 2027, pushing back the effective date of the Bureau of Industry and Security's Affiliates Rule. While the suspension delays immediate compliance obligations, the rule remains in place and companies should use this additional time to prepare their compliance programs before the suspension potentially expires.
GlobalInternational Law
Crowell & Moring LLP
Crowell & Moring LLP
Article

The Lindsey Graham Sanctions Act: What Businesses Need To Know About The New Tariffs

President Trump signed the Lindsey O. Graham Sanctioning Russia and Iran Act into law on September 18, 2026, establishing mandatory tariffs of up to 500% on Russian goods and up to 100% on goods from countries that continue to buy Russian energy. The Act targets major importers like China, India, and Turkey, with limited relief mechanisms including natural gas exceptions, presidential waivers, and a 270-day winddown period for entities divesting from Russian operations.
GlobalInternational Law
Crowell & Moring LLP
Crowell & Moring LLP
Article

Updates On Export Controls Impacting AI & Advanced Computing

The U.S. Department of Commerce's Bureau of Industry and Security issued guidance on May 31, 2026, clarifying licensing requirements for advanced computing items and AI technologies. The guidance maintains export restrictions for entities in certain countries while providing limited relief for data center operators, though questions remain about future regulatory direction. Companies must now strengthen their compliance programs and supply-chain due diligence as BIS continues to prioritize national security
GlobalInternational Law
Finnegan, Henderson, Farabow, Garrett & Dunner LLP
Finnegan, Henderson, Farabow, Garrett & Dunner LLP