Data, privacy and AI rules

Due in 60 days12Regulations190

12 due in 60 days · 190 regulations

DOJ Bulk Data Rule

In force United States (Federal) · In force Apr 8, 2025 · no upcoming deadlines

Official text
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Deadlines

ComplianceOct 6, 2025 · 13 months ago · Source
Due diligence, audit and reporting obligations applySubpart J (data compliance program, due diligence and audits for restricted transactions) and reporting requirements in 202.1103 and 202.1104 apply.
Takes effectApr 8, 2025 · 19 months ago · Source
Prohibitions and restrictions take effectCore prohibitions on covered data transactions and security requirements for restricted transactions apply.

Summaries for reference, not legal advice. Check the official text.

What it does

Prohibits U.S. persons from data brokerage and genomic-data transactions with countries of concern or covered persons, and restricts vendor, employment and investment agreements involving bulk U.S. sensitive personal data or government-related data unless CISA security requirements are met. Restricted transactions require a data compliance program, due diligence, audits, recordkeeping and reporting.

Who it applies to
U.S. persons (companies and individuals) engaging in covered data transactions with China (incl. Hong Kong and Macau), Cuba, Iran, North Korea, Russia or Venezuela, or covered persons. Bulk thresholds over the preceding 12 months: human genomic data on 100+ U.S. persons; other human 'omic data or biometric identifiers on 1,000+; precise geolocation on 1,000+ devices; personal health or personal financial data on 10,000+; covered personal identifiers on 100,000+. Government-related data has no threshold.
Penalties
Civil penalty up to the greater of $368,136 (as stated in the rule; inflation-adjusted) or twice the transaction value per violation; willful violations up to $1,000,000 in fines and, for individuals, up to 20 years' imprisonment (IEEPA).
Enforced by
U.S. Department of Justice, National Security Division
Official name
Preventing Access to U.S. Sensitive Personal Data and Government-Related Data by Countries of Concern or Covered Persons (28 CFR Part 202) - DOJ Data Security Program
Citation
28 CFR Part 202; 90 FR 1636 (Jan. 8, 2025); Executive Order 14117; IEEPA (50 U.S.C. 1701 et seq.)
Topics
Privacy, Data residency, Cybersecurity, Biometrics, Health data, Financial
Verified 2026-09-22 ecfr.gov justice.gov federalregister.gov
Research notes

DOJ announced a 90-day limited enforcement period after April 8, 2025 for good-faith efforts (per DOJ NSD policy, not re-verified here). An April 18, 2025 technical amendment (90 FR 16466) corrected the rule. Penalty figure is the one printed in the January 2025 rule.

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Questions about DOJ Bulk Data Rule
What are the DOJ Bulk Data Rule compliance deadlines?
Apr 8, 2025: Prohibitions and restrictions take effect. Oct 6, 2025: Due diligence, audit and reporting obligations apply.
When does DOJ Bulk Data Rule take effect?
DOJ Bulk Data Rule took effect on Apr 8, 2025.
Who does DOJ Bulk Data Rule apply to?
U.S. persons (companies and individuals) engaging in covered data transactions with China (incl. Hong Kong and Macau), Cuba, Iran, North Korea, Russia or Venezuela, or covered persons. Bulk thresholds over the preceding 12 months: human genomic data on 100+ U.S. persons; other human 'omic data or biometric identifiers on 1,000+; precise geolocation on 1,000+ devices; personal health or personal financial data on 10,000+; covered personal identifiers on 100,000+. Government-related data has no threshold.
What are the penalties under DOJ Bulk Data Rule?
Civil penalty up to the greater of $368,136 (as stated in the rule; inflation-adjusted) or twice the transaction value per violation; willful violations up to $1,000,000 in fines and, for individuals, up to 20 years' imprisonment (IEEPA).