Increased DOJ Scrutiny Expected With New Data Rule Provisions in Effect
Companies should expect increased DOJ scrutiny and possible data requests in late 2025, Marashlian & Donahue said in an alert Monday.
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New provisions under DOJ’s global data transfer rule came into effect Monday (see 2504140047), the firm noted. Among the newly active provisions: “diligence and audit requirements apply to restricted transactions, annual reports are required regarding restricted transactions and reports must be filed on rejected prohibited transactions.”
Companies engaging in restricted transactions must implement a data compliance program and conduct a rule-compliant audit, the firm said. Annual reporting is required for companies engaged in cloud-related restricted transactions that have 25% or more ownership by a country of concern or covered person. If a company rejects a transaction because of the rule, it must report it to DOJ within 14 days of the rejected transaction.
Venable, in a blog post, noted that companies must maintain “records of data compliance program; implementation of applicable security requirements; audits; covered transactions; and other specified documents.”