On January 8, 2025, the US Department of Justice (DOJ) issued a Final Rule(1) to implement Executive Order 14117 on “Preventing Access to Americans’ Bulk Sensitive Personal Data and United States Government-Related Data by Countries of Concern” (the EO).(2) The Final Rule categorically prohibits or restricts US persons from engaging in certain transactions that would result in access by countries of concern or covered persons to bulk US sensitive personal data and government-related data, and is reflective of the US government’s broader efforts to strategically decouple from China. The Final Rule will have broad implications for US companies across a range of sectors, as it relates to both internal operations and third-party transactions. The Final Rule largely takes effect on April 8, 2025, with certain compliance requirements entering into force on October 6, 2025.