USA Law and Practice Contributed by: G. J. Ligelis Jr., Christopher K. Fargo, Alyssa K. Caples and Margaret T. Segall, Cravath, Swaine & Moore LLP
International The EU–US Data Privacy Framework (and the UK Extension to the Framework) establishes a European Commission-approved mechanism for US companies to transfer personal data from the EU, the UK and Switzerland to the US without additional data protec - tion mechanisms, although the data is currently sub - ject to stricter European data privacy laws.
York, Oregon, Tennessee, Texas, Utah and Virginia have comprehensive consumer data privacy laws in effect. Additionally, Indiana, Kentucky and Rhode Island consumer data privacy laws will come into effect in early 2026. Because of the broad nature of these data privacy laws, they can have significant extraterritorial scope that captures non-resident busi - nesses. Penalties under state regulations vary, but include civil penalties levied on a per-violation basis. How - ever, because these state regulations are still rela - tively novel, enforcement is still evolving. Recently, several state-level privacy regulators have entered into an enforcement consortium aimed at harmonis - ing enforcement priorities and trends, and California’s privacy regulator has prioritised international enforce - ment collaboration efforts.
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