American companies with subsidiaries, operations, employees and customers located in Europe that transfer personal data from the EU and the European Economic Area (EEA) to locations outside the EU/EEA should be aware that the U.S.- EU Data Protection Safe Harbor has been invalidated by the Court of Justice of the European Union. An agreement in principle between the EU and the United States was reached in late October regarding a new Safe Harbor regime, which is expected to be implemented in January of 2016. In the meantime, companies impacted by the ruling need to begin planning how to best ensure ongoing compliance given the uncertainty regarding whether enforcement actions will be pursued and in anticipation of the heightened safeguards that will likely be imposed by the new pact.

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