ARTICLE · 19 MARCH 2024

DOJ Kicks Off Work To Regulate Foreign Access To Sensitive Personal Data Under New EO

Wiley Rein

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On March 5, 2024, the Department of Justice (DOJ) issued an Advance Notice of Proposed Rulemaking (ANPRM) regarding Access to Americans' Bulk Sensitive Personal Data and Government-Related Data by Countries of Concern.

United StatesGovernment, Public Sector

Daniel P. Brooks

Jacqueline F. "Lyn" Brown

Scott Bouboulis

On March 5, 2024, the Department of Justice (DOJ) issued an Advance Notice of Proposed Rulemaking (ANPRM) regarding Access to Americans' Bulk Sensitive Personal Data and Government-Related Data by Countries of Concern. The ANPRM follows Executive Order (EO) 14117, Preventing Access to Americans' Bulk Sensitive Personal Data and United States Government-Related Data by Countries of Concern (February 28, 2024), which directed the Attorney General to issue regulations prohibiting or restricting sensitive data transactions with covered countries. Comments are due to DOJ by April 19, 2024.

The DOJ's ANPRM proposes (1) prohibitions on covered data transactions, and (2) restrictions on certain covered data transactions. The DOJ is also considering creating a licensing regime that would authorize covered data transactions that would otherwise be prohibited or restricted under the new regulations.

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