How to Comply with the Bulk Data Rule for Restricted Transactions

• 1 Criteria that make a transaction prohibited versus classified as restricted under the Bulk Data Rule
• 2 The rule's broad definition of access, including logical, physical, decryption, and onward transfers
• 3 CISA security controls for restricted transactions: vendor documentation, network topology, allow lists, and identity governance
• 4 How to document and defend compliance using internal risk assessments, vendor contracts, retention rules, and remediation verification

Based on transcript analysis