DOJ’s rule governing international transfers of sensitive personal data to “countries of concern,” issued under Executive Order 14117, presents legal risks and challenges for companies across business sectors. The rule governs not only the sale or commercial exchange of data, but also vendor, employment, and investment agreements that give other parties access to data. This presentation covered how the rule applies, the consequences of engaging in data transactions that the rule prohibits or restricts, specific use cases that create particular risk, and what to expect in terms of enforcement as the effective date of the rule approaches.
Speaker:
- David Aaron
Senior Counsel, Perkins Coie
