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European Union privacy developments: GDPR enforcement, EDPB guidance, ePrivacy rules and the wider EU digital rulebook affecting US firms.

EU developments with attention to what reaches US businesses through extraterritorial scope.

Cross-Border Transfers

The EU-US Data Privacy Framework: Adequacy Status After Latombe

September 1, 2026

The adequacy decision underpinning EU-US data transfers has been through one court challenge and one periodic review. This post states the status of Implementing Decision 2023/1795 by its own terms, describes the redress mechanism it relies on, and takes the posture of the legal challenge from the General Court's judgment and the notice of appeal rather than from commentary.

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GDPR

When the GDPR Reaches a US Company, and What It Requires Once It Does

August 12, 2026

The GDPR reaches companies with no European office, no European entity and no European staff. Article 3 ties application to conduct rather than to presence. This guide covers the two extraterritorial triggers, the six lawful bases, what data subjects can require, the transfer rules, and the fine structure that makes the analysis matter.

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