On September 28, 2023, the Cyberspace Administration of China published the draft Provisions on Regulating and Promoting Cross-Border Data Flows (“Draft Provisions”) for public consultation, demonstrating that China is trying to strike a balance between enhancing data security and promoting data-driven economic growth. Multinational companies with cross-border data transfers involving China are recommended to revisit their previous analysis based on the changes introduced in the Draft Provisions.


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Photo of Evan Chuck Evan Chuck

Evan Chuck is a partner in the firm’s Los Angeles office and is a member of the firm’s International Trade and Corporate Groups. He leads the firm’s Asia practice and is also a director of the firm’s China office in Shanghai.

Evan has…

Evan Chuck is a partner in the firm’s Los Angeles office and is a member of the firm’s International Trade and Corporate Groups. He leads the firm’s Asia practice and is also a director of the firm’s China office in Shanghai.

Evan has more than 25 years of international trade and cross-border transactional experience. He has been a strategic advisor to Fortune 500 companies in structuring market entry, global supply chain and e-commerce strategies across the Asia-Pacific region. He has in-depth experience in China with cross-border acquisitions/dispositions, government regulatory compliance, and investigations. He advises major multinational companies on navigating the potential conflicts between and among U.S., E.U., and newly emerging Chinese law, including the Anti-foreign Sanctions Law, the PRC “Blocking Statute”, the PRC Export Control Law, Unreliable Entity List, the PRC Cybersecurity Law, and the PRC Data Security Law. He has also been representing a select group of large, multinational Chinese companies with complex U.S. transactional, tax, and regulatory issues. Evan works closely with the firm’s government affairs group and consulting group, Crowell & Moring International, to align global geo-political policy and strategy with cross-border legal advice.

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Photo of Kate Growley Kate Growley

Kate M. Growley (CIPP/US, CIPP/G) is a director with Crowell & Moring International and based in Hong Kong. Drawing from over a decade of experience as a practicing attorney in the United States, Kate helps her clients understand, navigate, and shape the policy…

Kate M. Growley (CIPP/US, CIPP/G) is a director with Crowell & Moring International and based in Hong Kong. Drawing from over a decade of experience as a practicing attorney in the United States, Kate helps her clients understand, navigate, and shape the policy and regulatory environment for some of the most complex data issues facing multinational companies, including cybersecurity, privacy, and digital transformation. Kate has worked with clients across every major sector, with particular experience in technology, health care, manufacturing, and aerospace and defense. Kate is a Certified Information Privacy Professional (CIPP) in both the U.S. private and government sectors by the International Association of Privacy Professionals (IAPP). She is also a Registered Practitioner with the U.S. Cybersecurity Maturity Model Certification (CMMC) Cyber Accreditation Body (AB).

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Photo of Zhiwei Chen Zhiwei Chen

Zhiwei Chen is a counsel in Crowell & Moring’s Shanghai office, where he is a member of the firm’s International Trade and Privacy & Cybersecurity groups. Zhiwei has more than a decade of experience advising multinational clients on a wide range of complex…

Zhiwei Chen is a counsel in Crowell & Moring’s Shanghai office, where he is a member of the firm’s International Trade and Privacy & Cybersecurity groups. Zhiwei has more than a decade of experience advising multinational clients on a wide range of complex customs, trade, data privacy, and regulatory issues.

Clients benefit from Zhiwei’s experience and insight in managing the risks and maximizing the opportunities associated with China’s increasing regulation of cross-border flow of goods, services, and data. He brings to clients an unusual blend of regulatory, transactional, and litigation experience, which makes him a trusted adviser on various complex China regulatory issues

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Photo of Christiana State Christiana State

Christiana State (CIPP/US, CIPP/E) is a senior counsel in Crowell & Moring’s San Francisco office and a member of the firm’s Corporate and Privacy & Cybersecurity groups. Christiana focuses her practice on counseling clients on technology and privacy matters. Christiana leverages a combination…

Christiana State (CIPP/US, CIPP/E) is a senior counsel in Crowell & Moring’s San Francisco office and a member of the firm’s Corporate and Privacy & Cybersecurity groups. Christiana focuses her practice on counseling clients on technology and privacy matters. Christiana leverages a combination of in-house counsel experience and electrical engineering training to guide emerging technology companies through transformational growth stages. Christiana represents technology companies, from start-ups to multinational corporations, in various industry segments, such as: AI/ML, cloud services, biometrics, semiconductors and computing architectures, gaming, AR/VR, drones, and EV charging.

Christiana brings a pragmatic and business-focused approach to her representations. Prior to Crowell, she spent over a decade serving as in-house counsel for various technology companies in Silicon Valley. In those roles, Christiana led cross-functional teams while managing global technology and intellectual property deals, product launches and related regulatory matters, and intellectual property strategies.

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