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.

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).