On April 8, 2025, a sweeping rule issued by the US Department of Justice (DOJ) will take effect. The rule imposes restrictions—and in some cases, outright prohibitions—on US companies in connection with certain types of data brokerage, vendor relationships, employment arrangements, and investment agreements involving six "countries of concern" and individuals or entities linked to them: China (including Hong Kong and Macau), Russia, Iran, North Korea, Cuba, and Venezuela.
On April 8, 2025, a sweeping rule issued by the
US Department of Justice (DOJ) will take effect. The rule imposes
restrictions—and in some cases, outright
prohibitions—on US companies in connection with certain types
of data brokerage, vendor relationships, employment arrangements,
and investment agreements involving six "countries of
concern" and individuals or entities linked to them: China
(including Hong Kong and Macau), Russia, Iran, North Korea, Cuba,
and Venezuela.
For additional background on the rule, please see our prior client alert.
The rule, which the DOJ may enforce through civil or criminal
penalties, applies to a broad range of US companies, including
those that rely on vendors, cloud providers, tracking technologies,
or employees based in countries of concern. Even indirect access to
sensitive data by a covered person may trigger compliance
obligations or prohibitions.
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