Global Cross-Border Data Transfers (Part 3)

In 2025, the U.S. Government’s policy statements and Executive Orders have had far-reaching impacts for government contractors and grant recipients. Although terminations, stop work orders, and de-scopes have affected private companies, non-profits, and universities doing business across multiple agencies, the U.S. Government’s policies relating to the U.S. Agency for International Development (USAID) has caused particular confusion and uncertainty relating to performance, compliance, and contractual procedure. Key questions have included the potential impacts of official and less formal communications from the U.S. Government, procedural issues arising from the move of certain functions to the U.S. Department of State, and the effect of various pending litigations. As businesses and organizations plan for 2026, the importance of preserving their rights and maximizing potential recovery opportunities remains paramount.