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Maturing Compliance with the Bulk Sensitive Data Rule (Data Security Program) before the July 8, 2025 Safe Harbor Expires

Debevoise Data Blog

Part 202), and July 8, 2025, when the recently-announced good-faith safe harbor expires. October 6, 2025: comply with subpart J and 202.1103 and 202.1104. All eyes are on the DOJ Bulk Sensitive Data Rule (28 C.F.R. national security. national security. According to DOJ, this is so that the private sector U.S.

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National Security Update: DOJ Unveils Rules Restricting Sensitive Bulk Data Transfers

Debevoise Data Blog

company and its foreign subsidiaries and transactions required by federal law or international agreements. Alleged violators may seek additional judicial review in federal district court. government activities, routine banking and investment financial services, transactions within a U.S. DOJ expects U.S.