COGR Responds to USDOJ’s Notice of Proposed Rulemaking—Provisions Pertaining to Preventing Access to U.S. Sensitive Personal Data and Government-Related Data by Countries of Concern or Covered Persons

COGR, representing over 220 U.S. research institutions, submitted comments on the Department of Justice’s proposed rule aimed at restricting access to U.S. sensitive personal and government-related data by countries of concern. COGR expresses concern that the rule’s lack of exemptions for non-federally funded, non-clinical research would severely hinder essential international public health and foundational research, potentially undermining the U.S.’s global scientific leadership. COGR recommends that the DOJ add appropriate exemptions for such research, clarify key definitions and requirements, ensure consistency in regulatory language, expand coverage of current exemptions, and provide sufficient lead time and support for compliance, in order to minimize adverse impacts on the research community and maintain the nation’s research preeminence.