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NO SAFE HARBOR IN GERMANY—FIRST FINES IMPOSED FOR RELYING ON SAFE HARBOR FOR DATA TRANSFERS

June 08, 2016

By Behnam Dayanim and Edward George*

*Summer Associate; Georgetown University Law Center (J.D. expected 2017)

The Safe Harbor provision has finally set sail. On Monday, the Hamburg Data Protection Authority (“Hamburg DPA”) announced that it has fined three companies an aggregate total of €28,000 ($31,928) for continuing to operate under the U.S.-E.U. Safe Harbor Framework. This is the first enforcement action by any European country since the European Court of Justice (“CJEU”) invalidated the Safe Harbor last October.