The newest trans-Atlantic data framework is the third attempt in the last 20 years to address data transfers between the U.S. and E.U. and is likely to face continued criticisms and legal challenges. In a guest article, Elizabeth McGinn, Sasha Leonhardt and Lauren Bomberger, attorneys at Buckley, explain that while the exact language has not yet been released, the parties’ statements to date point to some key conclusions that can help companies prepare for the final framework – and suggest areas to watch for further clarification. See our series on navigating data transfers post-Schrems II: Challenges and TIAs (Feb. 23, 2022); and SCCs and Supplementary Measures (Mar. 2, 2022).