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Two or three countries, side by side, one row per question. Pick up to 3.

Countries

RussiaChecked 18 August 2026

A copy must stayWork: Very highEnforcement: Active

In one paragraph: If you collect personal data from people in Russia, the database you collect it into must sit inside Russia. You may then send a copy abroad, but only after you tell the regulator first and only to a country on its approved list. The United States is not on that list. Breaking the storage rule costs up to 6 million roubles, about $75,000, and leaking data can now put a person in prison.
The catch: The 'copy may go abroad' part disappears in several industries. Payments, electronic money, biometrics, telecoms, internet messaging services, government systems and detailed mapping are hard walls: the data must stay in Russia and no copy may leave. Since 1 September 2025 any company running 'significant' critical infrastructure — which includes most banks, telecoms operators and large energy and health providers — must also run Russian-registered software on those systems.
Does this apply to me?: Yes. The law reaches a foreign company with no office in Russia. It applies whenever you process the personal data of Russian citizens under a contract with them, under any other agreement with them, or on the basis of their consent. There is no size or revenue threshold. Almost every organisation must also file a notice with the regulator before it starts processing, and file a second, separate notice before any data leaves the country.High confidence
Can the data leave the country?: A copy can leave, but the original must stay. When you collect personal data about Russian citizens, the database you record, store, update or retrieve it from has to be physically in Russia. Since 1 July 2025 the law says this as a flat ban on using databases outside Russia for those steps. After that, sending a copy abroad is a separate question with its own paperwork. Several industries are stricter still and allow no copy out at all.High confidence
What do I have to do to send it abroad?: Russia runs an approved-destinations list, so a transfer is banned unless the destination is on it. Before any data leaves you must send the regulator a separate written notice naming the countries, the data and the recipients, and you must first collect written assurances from the recipient about how it will protect the data. If the destination is on the approved list you may start as soon as the notice is sent. If it is not, you must wait, and in practice you will be refused. The United States is not on the list.High confidence
Who enforces this — and are they actually working?: Roskomnadzor, the federal communications and media supervisor, is the data protection regulator. It is a long-established federal service, fully staffed, and it is still issuing binding orders — its most recent inspection check-list order was published on the state legal portal in December 2025. It is not the only enforcer. The security service runs the national cyber-attack reporting system, the technical regulator FSTEC sets security requirements for government and critical systems, and the Bank of Russia supervises banks and payment firms.Medium confidence
How long must I keep it, and when must I delete it?: Both directions apply and they collide. Personal data must be destroyed within 30 days of the purpose being achieved, or within 30 days of consent being withdrawn, and within 10 working days if the processing was unlawful. Against that, staff records must be kept for 50 years, telecoms and messaging metadata for three years, and message content for up to six months. Where a statute sets a minimum, the minimum wins and you keep the data.High confidence
What happens when something goes wrong?: There are at least three clocks and they run at once. You have 24 hours to tell the data regulator that personal data has leaked, and 72 hours to give it the results of your internal investigation. Separately, if the leak came from a computer attack you must report it to the security service's national attack-detection system. Banks and payment firms report to the Bank of Russia as well. Missing the 24-hour notice is itself a fine of up to 3 million roubles, about $37,000.High confidence
What's the trap?: Five things catch people out. First, leaking data is now a crime, and doing it across a border carries up to eight years in prison. Second, repeat leaks are fined as a share of worldwide-style annual revenue, between 1 and 3 percent, with a floor of 20 million roubles, about $250,000. Third, staff files must be kept 50 years, which flatly conflicts with the 30-day deletion duty. Fourth, biometric data can only be handled by a Russian-controlled company using databases in Russia. Fifth, refusing to serve a customer because they will not give biometrics is itself a fine.High confidence
What's about to change?: One dated change is already fixed: from 1 September 2027, Moscow's public bodies move onto a single city technology platform, which will pull a large volume of citizen data into one place. Much more important are the switches the government already holds and can flip with no consultation. The approved-country list can be cut by a single regulator order. Any transfer can be banned outright on security or economic grounds. And the rules for foreign use of Russian mapping technology have been written into the law but never issued.High confidence
Hardest industry wall: All industries — Федеральный закон от 27.07.2006 № 152-ФЗ «О персональных данных», статья 18 часть 5
All industries — Федеральный закон № 152-ФЗ, статья 21 часть 3.1 и статья 19 часть 12
All industries — Уголовный кодекс Российской Федерации, статья 272.1
Payments — Федеральный закон от 27.06.2011 № 161-ФЗ «О национальной платежной системе», статьи 12 и 16
All industries — Федеральный закон от 29.12.2022 № 572-ФЗ об идентификации и аутентификации с использованием биометрических персональных данных
Telecoms — Федеральный закон от 07.07.2003 № 126-ФЗ «О связи», статья 64; Федеральный закон от 27.07.2006 № 149-ФЗ, статья 10.1
Government — Приказ ФСТЭК России от 11.04.2025 № 117; Указ Президента РФ от 30.03.2022 № 166; Указ Президента РФ от 01.05.2022 № 250; Федеральный закон от 07.04.2025 № 58-ФЗ
Mapping and location — Федеральный закон от 30.12.2015 № 431-ФЗ «О геодезии, картографии и пространственных данных», статьи 23 и 24
Health and social care — Федеральный закон от 21.11.2011 № 323-ФЗ «Об основах охраны здоровья граждан в Российской Федерации», статья 13
Social media and online platforms — Федеральный закон от 01.07.2021 № 236-ФЗ «О деятельности иностранных лиц в информационно-телекоммуникационной сети «Интернет» на территории Российской Федерации»

United StatesChecked 18 August 2026

Depends on your industryWork: HighEnforcement: Active

In one paragraph: In general the United States lets data go anywhere. There is no national privacy law and no permit is needed to move data abroad. Two things bite hard. Six countries are effectively off limits for large amounts of sensitive data, with prison sentences attached. And anything connected to government work must physically stay on American soil.
The catch: The open headline stops the moment you touch one of six areas: government contracting, police records, federal tax records, defence technical data, telecom licences, and bulk sensitive data flowing to China, Russia, Iran, North Korea, Cuba or Venezuela. Also note that the rule that actually binds you is almost always a state law or an industry regulator's rule, not a national privacy act. There isn't one.
Does this apply to me?: Yes. American rules reach a foreign company with no office in the country. California's privacy law applies to any for-profit business that 'does business in California' and crosses one of three thresholds, and physical presence is not one of them. The children's rule covers foreign websites aimed at American children. No state and no federal law requires you to appoint a local representative — a real difference from Europe.High confidence
Can the data leave the country?: It depends entirely on your industry, so the single national answer is misleading. For ordinary consumer or employee data, yes — send it anywhere, no paperwork. But six sectors have hard walls. Government contracting, police data, federal tax data and defence work require the data to physically stay in the United States. Telecom licences restrict which foreign staff may even look at records. And for anyone, sending large volumes of sensitive data to six named countries is now a crime.High confidence
What do I have to do to send it abroad?: For ordinary data, nothing. No standard contract, no government approval, no destination approval list. The model is a blocklist and it is now populated: six countries are named. Before you move large volumes of sensitive data, your only real job is to work out whether a country of concern, or a company or person they control, could end up with access — including through a vendor, an investor or an employee.High confidence
Who enforces this — and are they actually working?: Nobody, and everybody. There is no national privacy regulator. Instead the consumer protection regulator, the health department, the securities regulator, the communications regulator, the Justice Department, all fifty state attorneys general and one dedicated state privacy agency each enforce a slice. Almost all of them are visibly working right now. The one exception is the new national data transfer programme: it is staffed and issuing guidance but has published no enforcement action yet.High confidence
How long must I keep it, and when must I delete it?: There is a strong floor and a weak but growing ceiling. Investment firms must keep some books for six years and most others for three, with the first two years easy to reach. Health providers keep their paperwork for six years. In the other direction, state privacy laws now force you to publish how long you keep each type of data and to stop keeping it longer than you said, and since April 2026 children's data may no longer be kept indefinitely. Where a keep-it rule and a delete-it rule collide, the keep-it rule wins: every state law carves out data you are required by law to retain.High confidence
What happens when something goes wrong?: Count the clocks — there are at least seven, and they disagree. New York financial firms: 72 hours to the state regulator, and only 24 hours to report paying a ransom. Telecom carriers: seven working days to the police agencies and the communications regulator, and you may not warn customers until seven working days after that. Investment and finance firms: 30 days to affected customers. Health organisations: 60 days. Texas and many other states: 30 days to the state attorney general. Listed companies: four working days to disclose a material incident. The overlap, not any single deadline, is what people fail.High confidence
What's the trap?: Five that cost people their weekend. One: the national data transfer programme carries prison — up to twenty years for a deliberate breach. Two: Illinois lets individuals sue over fingerprints and face scans with fixed damages per person, no proof of harm needed, and that is where the largest privacy payouts happen. Three: the children's rule uses under 13, but several state laws use under 18, so a single age gate will not do. Four: government work means American soil, and police data allows only the United States, its territories, tribal lands and Canada. Five: a rule can be printed in the law book and still be unenforceable, because a court has blocked it.High confidence
What's about to change?: Four things in the next twelve months. The national critical infrastructure reporting rule should be finalised in late 2026, which will switch on a 72-hour incident clock and a 24-hour ransom-payment clock for a very wide range of businesses. California's rules on automated decision-making bite on 1 January 2027. The open banking rule is being rewritten after a court blocked it. And a federal privacy bill is moving in Congress, but it is only a bill and binds nobody.High confidence
Hardest industry wall: Government — Criminal Justice Information Services (CJIS) Security Policy
Government — Publication 1075, Tax Information Security Guidelines for Federal, State and Local Agencies
Defence — Defense Federal Acquisition Regulation Supplement clause 252.239-7010, Cloud Computing Services
Telecoms — National security agreement / letter of assurance conditioning a section 214 authorisation, reviewed by the Committee for the Assessment of Foreign Participation in the United States Telecommunications Services Sector

The eight framework questions answered for each selected country
Question	RussiaChecked 18 August 2026	United StatesChecked 18 August 2026
The three ratings	A copy must stay Work: Very high Enforcement: Active	Depends on your industry Work: High Enforcement: Active
In one paragraph	If you collect personal data from people in Russia, the database you collect it into must sit inside Russia. You may then send a copy abroad, but only after you tell the regulator first and only to a country on its approved list. The United States is not on that list. Breaking the storage rule costs up to 6 million roubles, about $75,000, and leaking data can now put a person in prison.	In general the United States lets data go anywhere. There is no national privacy law and no permit is needed to move data abroad. Two things bite hard. Six countries are effectively off limits for large amounts of sensitive data, with prison sentences attached. And anything connected to government work must physically stay on American soil.
The catch	The 'copy may go abroad' part disappears in several industries. Payments, electronic money, biometrics, telecoms, internet messaging services, government systems and detailed mapping are hard walls: the data must stay in Russia and no copy may leave. Since 1 September 2025 any company running 'significant' critical infrastructure — which includes most banks, telecoms operators and large energy and health providers — must also run Russian-registered software on those systems.	The open headline stops the moment you touch one of six areas: government contracting, police records, federal tax records, defence technical data, telecom licences, and bulk sensitive data flowing to China, Russia, Iran, North Korea, Cuba or Venezuela. Also note that the rule that actually binds you is almost always a state law or an industry regulator's rule, not a national privacy act. There isn't one.
Does this apply to me?	Yes. The law reaches a foreign company with no office in Russia. It applies whenever you process the personal data of Russian citizens under a contract with them, under any other agreement with them, or on the basis of their consent. There is no size or revenue threshold. Almost every organisation must also file a notice with the regulator before it starts processing, and file a second, separate notice before any data leaves the country.High confidence	Yes. American rules reach a foreign company with no office in the country. California's privacy law applies to any for-profit business that 'does business in California' and crosses one of three thresholds, and physical presence is not one of them. The children's rule covers foreign websites aimed at American children. No state and no federal law requires you to appoint a local representative — a real difference from Europe.High confidence
Can the data leave the country?	A copy can leave, but the original must stay. When you collect personal data about Russian citizens, the database you record, store, update or retrieve it from has to be physically in Russia. Since 1 July 2025 the law says this as a flat ban on using databases outside Russia for those steps. After that, sending a copy abroad is a separate question with its own paperwork. Several industries are stricter still and allow no copy out at all.High confidence	It depends entirely on your industry, so the single national answer is misleading. For ordinary consumer or employee data, yes — send it anywhere, no paperwork. But six sectors have hard walls. Government contracting, police data, federal tax data and defence work require the data to physically stay in the United States. Telecom licences restrict which foreign staff may even look at records. And for anyone, sending large volumes of sensitive data to six named countries is now a crime.High confidence
What do I have to do to send it abroad?	Russia runs an approved-destinations list, so a transfer is banned unless the destination is on it. Before any data leaves you must send the regulator a separate written notice naming the countries, the data and the recipients, and you must first collect written assurances from the recipient about how it will protect the data. If the destination is on the approved list you may start as soon as the notice is sent. If it is not, you must wait, and in practice you will be refused. The United States is not on the list.High confidence	For ordinary data, nothing. No standard contract, no government approval, no destination approval list. The model is a blocklist and it is now populated: six countries are named. Before you move large volumes of sensitive data, your only real job is to work out whether a country of concern, or a company or person they control, could end up with access — including through a vendor, an investor or an employee.High confidence
Who enforces this — and are they actually working?	Roskomnadzor, the federal communications and media supervisor, is the data protection regulator. It is a long-established federal service, fully staffed, and it is still issuing binding orders — its most recent inspection check-list order was published on the state legal portal in December 2025. It is not the only enforcer. The security service runs the national cyber-attack reporting system, the technical regulator FSTEC sets security requirements for government and critical systems, and the Bank of Russia supervises banks and payment firms.Medium confidence	Nobody, and everybody. There is no national privacy regulator. Instead the consumer protection regulator, the health department, the securities regulator, the communications regulator, the Justice Department, all fifty state attorneys general and one dedicated state privacy agency each enforce a slice. Almost all of them are visibly working right now. The one exception is the new national data transfer programme: it is staffed and issuing guidance but has published no enforcement action yet.High confidence
How long must I keep it, and when must I delete it?	Both directions apply and they collide. Personal data must be destroyed within 30 days of the purpose being achieved, or within 30 days of consent being withdrawn, and within 10 working days if the processing was unlawful. Against that, staff records must be kept for 50 years, telecoms and messaging metadata for three years, and message content for up to six months. Where a statute sets a minimum, the minimum wins and you keep the data.High confidence	There is a strong floor and a weak but growing ceiling. Investment firms must keep some books for six years and most others for three, with the first two years easy to reach. Health providers keep their paperwork for six years. In the other direction, state privacy laws now force you to publish how long you keep each type of data and to stop keeping it longer than you said, and since April 2026 children's data may no longer be kept indefinitely. Where a keep-it rule and a delete-it rule collide, the keep-it rule wins: every state law carves out data you are required by law to retain.High confidence
What happens when something goes wrong?	There are at least three clocks and they run at once. You have 24 hours to tell the data regulator that personal data has leaked, and 72 hours to give it the results of your internal investigation. Separately, if the leak came from a computer attack you must report it to the security service's national attack-detection system. Banks and payment firms report to the Bank of Russia as well. Missing the 24-hour notice is itself a fine of up to 3 million roubles, about $37,000.High confidence	Count the clocks — there are at least seven, and they disagree. New York financial firms: 72 hours to the state regulator, and only 24 hours to report paying a ransom. Telecom carriers: seven working days to the police agencies and the communications regulator, and you may not warn customers until seven working days after that. Investment and finance firms: 30 days to affected customers. Health organisations: 60 days. Texas and many other states: 30 days to the state attorney general. Listed companies: four working days to disclose a material incident. The overlap, not any single deadline, is what people fail.High confidence
What's the trap?	Five things catch people out. First, leaking data is now a crime, and doing it across a border carries up to eight years in prison. Second, repeat leaks are fined as a share of worldwide-style annual revenue, between 1 and 3 percent, with a floor of 20 million roubles, about $250,000. Third, staff files must be kept 50 years, which flatly conflicts with the 30-day deletion duty. Fourth, biometric data can only be handled by a Russian-controlled company using databases in Russia. Fifth, refusing to serve a customer because they will not give biometrics is itself a fine.High confidence	Five that cost people their weekend. One: the national data transfer programme carries prison — up to twenty years for a deliberate breach. Two: Illinois lets individuals sue over fingerprints and face scans with fixed damages per person, no proof of harm needed, and that is where the largest privacy payouts happen. Three: the children's rule uses under 13, but several state laws use under 18, so a single age gate will not do. Four: government work means American soil, and police data allows only the United States, its territories, tribal lands and Canada. Five: a rule can be printed in the law book and still be unenforceable, because a court has blocked it.High confidence
What's about to change?	One dated change is already fixed: from 1 September 2027, Moscow's public bodies move onto a single city technology platform, which will pull a large volume of citizen data into one place. Much more important are the switches the government already holds and can flip with no consultation. The approved-country list can be cut by a single regulator order. Any transfer can be banned outright on security or economic grounds. And the rules for foreign use of Russian mapping technology have been written into the law but never issued.High confidence	Four things in the next twelve months. The national critical infrastructure reporting rule should be finalised in late 2026, which will switch on a 72-hour incident clock and a 24-hour ransom-payment clock for a very wide range of businesses. California's rules on automated decision-making bite on 1 January 2027. The open banking rule is being rewritten after a court blocked it. And a federal privacy bill is moving in Congress, but it is only a bill and binds nobody.High confidence
Hardest industry wall	All industries — Федеральный закон от 27.07.2006 № 152-ФЗ «О персональных данных», статья 18 часть 5 All industries — Федеральный закон № 152-ФЗ, статья 21 часть 3.1 и статья 19 часть 12 All industries — Уголовный кодекс Российской Федерации, статья 272.1 Payments — Федеральный закон от 27.06.2011 № 161-ФЗ «О национальной платежной системе», статьи 12 и 16 All industries — Федеральный закон от 29.12.2022 № 572-ФЗ об идентификации и аутентификации с использованием биометрических персональных данных Telecoms — Федеральный закон от 07.07.2003 № 126-ФЗ «О связи», статья 64; Федеральный закон от 27.07.2006 № 149-ФЗ, статья 10.1 Government — Приказ ФСТЭК России от 11.04.2025 № 117; Указ Президента РФ от 30.03.2022 № 166; Указ Президента РФ от 01.05.2022 № 250; Федеральный закон от 07.04.2025 № 58-ФЗ Mapping and location — Федеральный закон от 30.12.2015 № 431-ФЗ «О геодезии, картографии и пространственных данных», статьи 23 и 24 Health and social care — Федеральный закон от 21.11.2011 № 323-ФЗ «Об основах охраны здоровья граждан в Российской Федерации», статья 13 Social media and online platforms — Федеральный закон от 01.07.2021 № 236-ФЗ «О деятельности иностранных лиц в информационно-телекоммуникационной сети «Интернет» на территории Российской Федерации»	Government — Criminal Justice Information Services (CJIS) Security Policy Government — Publication 1075, Tax Information Security Guidelines for Federal, State and Local Agencies Defence — Defense Federal Acquisition Regulation Supplement clause 252.239-7010, Cloud Computing Services Telecoms — National security agreement / letter of assurance conditioning a section 214 authorisation, reviewed by the Committee for the Assessment of Foreign Participation in the United States Telecommunications Services Sector