On October 29, 2024, the Department of Justice (DOJ) published its Proposed Rule outlining prohibitions and restrictions on certain transactions involving bulk U.S. sensitive personal data and U.S. Government-related data. As you may recall from our previous article, this rule stems from recent Executive Order (EO) 14117 on “Preventing Access to Americans’ Bulk Sensitive Personal Data and United States Government-Related Data by Countries of Concern.” The Proposed Rule has potential implications for any business that collects, retains, or deals in data on U.S. persons or certain other data relating to the U.S. Government. Here, we discuss some of the more interesting developments in the Proposed Rule and how it could affect your business.
