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Covington has extensive experience assisting with cross-border transfer issues, including advising on binding corporate rules (BCRs) and on the “Safe Harbor” regime for data transfers from the EU to the U.S. In the past few years alone, we have assisted a number of clients in preparing their BCR submissions, enabled numerous companies to enroll in or re-certify to the Safe Harbor, and have prepared and filed (where necessary) international data transfer agreements in most EU jurisdictions. In addition, the Covington team is expert in the Cross Border Privacy Rules (CBPR) System deployed by the Asia-Pacific Economic Cooperation (APEC) economies.

Covington’s experience with BCRs is especially substantial. Our experience encompasses all stages of BCRs, from assisting clients with internal preparation of the company, the designation of a lead authority, the drafting of the BCRs and supporting documentation, the submission of the BCR application with the lead authority and subsequent implementation, including national registration and roll-out of the individual elements of the BCR package.