The DOJ Sensitive Data Rule: A Race to Compliance Maturity
On October 6, 2025, the final provisions of the DOJ Sensitive Data Rule took effect, completing the framework for the DOJ’s Data Security Program. Institutions engaging in relevant data-sharing activities should move quickly to ensure compliance. On October 6, 2025, the last provisions of 28 C.F.R. Part 202, “ Access to U.S. Sensitive Personal Data and Government-Related Data by Countries of Concern or Covered Persons ” (“DOJ Rule”) took effect, completing the regulatory
Alan Grose, XL Law Consulting
1 day ago6 min read
DOJ Publishes Guidance, Announces Additional 90-Days for Good Faith Efforts to Comply with Sensitive Data Rule
On April 11, 2025, the DOJ National Security Division published new guidance regarding the U.S. Sensitive Personal Data and...
Alan Grose and Emma Bahner, XL Law Consulting
Apr 295 min read
DOJ Issues National Security Regulation to Limit Transfers of Sensitive Data to Countries of Concern
On January 8, 2025, the DOJ issued a new final rule to prohibit or restrict transfers of bulk sensitive personal data and certain U.S....
Alan Grose and Emma Bahner, XL Law Consulting
Mar 1311 min read
Blockchains, NFT Diplomas, and Data Privacy – Oh My!
By now, nearly everyone has heard of “blockchains” and “NFTs,” and some universities are even using them to issue and validate...
Emma Bahner, XL Law & Consulting
Jun 20, 20236 min read
