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U.S.-EU Safe Harbor Renegotiation Deadline Passes: What Now?

Client Alert | 1 min read | 02.01.16

Despite intensive last-minute talks over the weekend, U.S. and European Union (EU) negotiators have yet to reach a new agreement for the legitimization of data transfers from Europe to the United States to replace the invalidated U.S.-EU Safe Harbor Framework (Safe Harbor). On February 1, EU Commissioner Věra Jourová provided a status update at a plenary meeting of the European Parliament's Committee on Civil Liberties, Justice and Home Affairs (LIBE) in Brussels. Jourová told the Parliament committee, "I believe the close relationship between the United States and European Union deserves these special efforts. We are close but an additional effort is needed." Negotiators on both sides still hope to find an agreement this week.

In the meantime, the EU Member States' Data Protection authorities (Article 29 Working Party) will meet on February 2 to discuss how to proceed. The meeting will include discussions about investigations and possible suspensions of data transfers which continue based solely on the former Safe Harbor. The authorities will also assess other transfer mechanisms such as EU Standard Contractual Clauses and Binding Corporate Rules, which also have been criticized based on the same concerns relating to U.S. government surveillance.

We will provide additional guidance as it becomes available.

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Client Alert | 2 min read | 07.15.26

CMMC Phase II Suspension Requires Reconsideration of Such Requirements in Solicitations

As discussed in more detail here, the U.S. Department of War (DoW) recently issued a memorandum (Memo 26-P-1023, dated July 13, 2026) directing the immediate suspension of Cybersecurity Maturity Model Certification (CMMC) Phase II requirements (Level I and II self assessments are still permitted). Significantly, the memo directs that “all pending and future CMMC implementation milestones across DoW solicitations and contracts are held in abeyance until further notice.” Moreover, the DoW issued a memorandum on implementing these requirements (available here), directing agencies to issue amendments removing CMMC Level 2 and 3 requirements from active solicitations “as soon as practicable.” Contractors should monitor the government’s compliance with this requirement and should be prepared, if needed, to file a bid protest to protect their rights....

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