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AI & Privacy/Federal/28 CFR 202; 90 FR 1636

DOJ Data Security Program — countries-of-concern data transactions

Enacted in force

Jurisdiction
Federal [source]
Applies to
U.S. persons engaging in defined covered data transactions involving bulk U.S. sensitive personal data or U.S. government-related data and countries of concern or covered persons. Transaction categories, data thresholds, exemptions and licensing rules control; this is not a general ban on all cross-border data flows. [source]
Penalty
Civil and, for willful violations, criminal enforcement under IEEPA and 28 CFR 202 subpart M; current adjusted dollar amounts not independently verified. [source]
Detail review
Accepted record facts reviewed
Nov 13, 2026

Fields requiring verification

In plain English

Dates and phased obligations

Legal effective / principal operative date: 2025-04-08. Sections 202.1001–1002 and 202.1103–1104 apply to the relevant transactions from 2025-10-06. Primary source

· operative
Legal effective / principal operative date: 2025-04-08. Sections 202.1001–1002 and 202.1103–1104 apply to the relevant transactions from 2025-10-06. Primary source

The final rule and codified section 202.216 identify April 8, 2025 as the legal effective date. Due diligence and audit requirements in sections 202.1001–1002 and specified reporting requirements in sections 202.1103–1104 apply to relevant transactions (or rejected proposed transactions) on or after October 6, 2025. No claim is made that every reporting provision started in October. Source and qualifications

Questions from this record

Who does 28 CFR 202; 90 FR 1636 cover?

U.S. persons engaging in defined covered data transactions involving bulk U.S. sensitive personal data or U.S. government-related data and countries of concern or covered persons. Transaction categories, data thresholds, exemptions and licensing rules control; this is not a general ban on all cross-border data flows. Primary source

What is the law’s status?

Enacted / in force Primary source

What date does this record track?

Legal effective / principal operative date: 2025-04-08. Sections 202.1001–1002 and 202.1103–1104 apply to the relevant transactions from 2025-10-06. Primary source

Has this record been verified?

This record’s accepted facts were last reviewed on 2026-11-13; unsupported comparison fields remain Unverified. Primary source

Primary sources

Verification history

Not legal advice. This page restates the linked record and does not determine whether a particular business is covered. Methodology and verification limits.

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