On April 8, 2025, the Division of Justice’s remaining rule implementing Executive Order 14117 (“Last Rule”) went into impact, except for sure due diligence, audit and reporting obligations that may take impact on October 5, 2025. The Last Rule restricts the majority switch of delicate U.S. private and authorities information to sure international locations and individuals of concern.
The Last Rule establishes a nationwide safety regulatory regime that both prohibits or restricts “lined information transactions,” that are sure transactions (i.e., information brokerage, employment agreements, funding agreements and vendor agreements) that might lead to entry to bulk U.S. delicate private information or government-related information by (1) a “nation of concern” (i.e., China, Cuba, Iran, North Korea, Russia and Venezuela) or (2) a “lined individual” (e.g., an entity with 50% or extra possession by a rustic of concern, an entity organized underneath the legal guidelines of, or with their principal workplace in, a rustic of concern, or a international individual that’s an worker or contractor of such entity or a major resident of a rustic of concern).
Learn our previous coverage of the Final Rule.
