USA LAW AND PRACTICE Contributed by: Nancy Libin, David Rice, Spencer Persson, Michael Borgia, Robert Stankey, Kara Trowell and Alexander Sisto, Davis Wright Tremaine LLP
5.3 Data Localisation Requirements There are no general localisation requirements for personal data under US law. However, sec - tor-specific laws and regulations may have the effect of requiring certain types of information to be kept within US territory. 5.4 Blocking Statutes See 5.2 Government Notifications and Approv - als . 5.5 Recent Developments See 5.1 Restrictions on International Data Transfers .
administration’s Executive Order on Preventing Access to Americans’ Bulk Sensitive Personal Data and United States Government-Related Data by Countries of Concern. The restrictions apply to transactions involving sensitive per - sonal data that exceeds certain bulk volume thresholds. The current “countries of concern” are China, Cuba, Iran, North Korea, Russia and Venezuela. Sensitive personal data includes pre - cise geolocation information, biometric identifi - ers, human genomic data, personal health data, personal financial data and personal identifiers (eg, names linked to advertising IDs). 5.2 Government Notifications and Approvals The Committee on Foreign Investment in the United States (CFIUS), a division of the US Department of Treasury, can block transactions that could allow foreign adversaries access to US sensitive personal data. Indeed, in Septem - ber 2022, President Biden signed the Execu - tive Order on Ensuring Robust Consideration of Evolving National Security Risks by the Commit - tee on Foreign Investment in the United States (CFIUS), which, among other things, directed the CFIUS to scrutinise transactions involving sensi - tive personal data.
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