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ARTICLE · 29 OCTOBER 2025

The DOJ Bulk Data Transfer Rule: Are You Subject To It And What Does It Require?

Jackson Lewis P.C.
Jackson Lewis P.C.
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The lengthy and complex "Bulk Data Transfer Rule," more formally known as the "Rule Preventing Access to U.S. Sensitive Personal Data and Government-Related Data by Countries of Concern...

United StatesPrivacy
Joseph Lazzarotti
Joseph Lazzarotti
Damon Silver
Damon Silver
Mary T. Costigan
Mary T. Costigan
Jason C. Gavejian
Jason C. Gavejian

Takeaways

  • The "Bulk Data Transfer Rule" prohibits or restricts sending sensitive data to "countries of concern" or certain persons located in or associated with them, including vendors and contractors.
  • Those covered by the rule must maintain certain data security requirements.
  • The DOJ has released guidance documents.

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Article

The lengthy and complex "Bulk Data Transfer Rule," more formally known as the "Rule Preventing Access to U.S. Sensitive Personal Data and Government-Related Data by Countries of Concern or Covered Persons," may apply to organizations even if they are not tech giants or data brokers. The wide-ranging federal rule establishing data transfer restrictions

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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.

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