Today, the Department of Justice’s (“DOJ”) Final Rule implementing former President Biden’s Executive Order 14117, “Preventing Access to Americans’ Bulk Sensitive Personal Data and United States Government-Related Data by Countries of Concern” (the “Final Rule”) took effect.
Earlier this year, Ropes & Gray published an alert providing an overview of the Final Rule, material changes from the DOJ’s Notice of Proposed Rulemaking (“NPRM”), and guidance on steps organizations should take to come into compliance. (Ropes & Gray also published alerts on the NPRM and the Advance Notice of Proposed Rulemaking).
If they haven’t already, organizations should evaluate their obligations under the Final Rule and make compliance changes accordingly.