Navigating Data Compliance Challenges: A Road Map on Bulk Sensitive Data Rules
Mingming Lu, LLM '26
Background
In recent years, it has become increasingly complex for multinational companies to navigate the maze of data compliance challenges. On April 8, 2025, the U.S. Department of Justice (“DOJ”) issued a final rule (“Final Rule”) implementing Executive Order 14117, entitled “Preventing Access to Americans’ Bulk Sensitive Personal Data and United States Government-Related Data by Countries of Concern.” Entities and individuals were expected to fully comply with the Final Rule starting...