Lexology March 7, 2024
Recently, cross-border data transfer regulatory policies in both the US and China have shown divergent trends. The Chinese government has adopted a policy orientation that is strict yet increasingly accommodating, actively responding to the demands of foreign enterprises and exploring a dual model of “post-approval flow + free flow.” On the other hand, in the US, President Biden signed the Executive Order on Preventing Access to Americans’ Bulk Sensitive Personal Data and United States Government-Related Data by Countries of Concern on February 28. The US Department of Justice issued a fact sheet on proposed rulemaking associated with this Executive Order on the same day. Future transactions involving a significant volume of human genomic data, personal health data, and other sensitive...
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