Maturing Compliance with the Bulk Sensitive Data Rule (Data Security Program) before the July 8, 2025 Safe Harbor Expires
Debevoise Data Blog
MAY 28, 2025
Informal Consultation Encouraged During this time, NSD will still pursue penalties and other enforcement actions as appropriate for egregious, willful violations. Of note, DOJ points out that [g]enerally, absent indications of evasion, conspiracy, or knowingly directing prohibited transactions, U.S. person fails to detect such violations.
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