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John Carlin, Rush Atkinson and Sam Kleiner Publish Bloomberg Law Article on Proposed Bulk Sensitive Data Rule

March 19, 2024

Litigation partners John Carlin and Rush Atkinson and associate Sam Kleiner published an article in Bloomberg Law on President Biden’s recent executive order limiting the transfer of sensitive U.S. personal data, which closes a significant gap in the government’s regulation of personal data. In “Bulk Sensitive Data Transfer Rule Would Tighten Security Controls,” published on March 19, the authors note that U.S. national security officials have become increasingly concerned about the risks related to the sale of sensitive personal information to foreign actors. They discuss a proposed DOJ rule in response to the executive order, which would prohibit certain types of transactions and subject other transactions to security-related restrictions through a new regulatory system, and they provide recommendations for how companies can prepare for any changes.

The authors further note that this executive order is representative of a trend over the past 15 years in which presidents have been invoking national security to develop new regulatory frameworks. “We expect that this broadening of national security regulation by the executive will continue,” they write.

Litigation associate Cole Rabinowitz assisted in the preparation of this article.

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© 2024 Paul, Weiss, Rifkind, Wharton & Garrison LLP

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