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DOJ’s Bulk Data Transfer Rule reshapes compliance across sectors

September 11, 2025

📝Editor’s Note

Regulators are increasing the stakes when it comes to data security. New U.S. rules demand tighter controls over bulk data transfers and risk heavy penalties for noncompliance. Compliance teams can no longer treat data governance as a back-office issue—it’s now essential in board-room strategy.

DOJ’s Bulk Data Transfer Rule reshapes compliance across sectors

The U.S. Department of Justice has introduced a new Bulk Data Transfer Rule, effective in April 2025, that imposes stricter compliance obligations for all entities transferring large amounts of "sensitive personal" or "government-related" data, especially when dealing with certain countries of concern. However, many key rules, like due diligence, audits, and reporting, become effective from Oct 6, 2025. 

Key concerns include identifying the data categories (e.g. biometrics, health records, financial data), mapping how such data flows internally and to third parties, and ensuring contracts with vendors forbid transfers to restricted jurisdictions. Civil penalties may be steep, up to twice the transaction value or fixed amounts, and criminal penalties are possible for willful violations.

Firms should treat this as more than just legal compliance: it’s now central to risk management, vendor oversight, and cross-border operations.

✅ Best Practice Spotlight

Strengthening Controls under New Data Transfer Standards

  1. Map all data flows—both internal and through vendors—to see exposures.

  2. Screen vendors and partners for connections to restricted jurisdictions.

  3. Update contracts to prohibit unauthorized bulk transfers and require compliance certifications.

  4. Develop internal audit programs and reporting obligations for relevant data transfers.

  5. Train staff on definitions of “sensitive personal data” and “government-related data,” and on consequences of noncompliance.

🛠️ Tool of the Week

Carbon Management Software

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  • Tracks scope 1, 2, and 3 emissions across operations and supply chain.

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🌟 Leader Spotlight

VMFS USA sets new standard for secure vending with advanced age verification tech

VMFS USA has introduced a next-generation age verification solution that applies biometric and behavior-based checks to secure vending machines. This solution goes beyond simple ID verification, incorporating real-time risk signals and AI-enabled anomaly detection to ensure compliance with age-restricted product laws. In doing so, VMFS not only addresses regulatory requirements but also sets a precedent for how automated systems can embed compliance features deeply into public-facing operations.

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