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DCC · DATA COMPLIANCE CHINA China data law, for overseas counsel.
§ TAG · MICRON

Filed under micron

Every brief tagged "micron".

  • § 01 · CYBERSECURITY-REVIEW

    China Opens a Cybersecurity Review of Palo Alto Networks: The Micron Playbook, Now Pointed at Firewalls

    On 6 August 2026 the Cybersecurity Review Office announced a cybersecurity review of Palo Alto Networks (派拓公司) products sold in China, citing the National Security Law, the Cybersecurity Law and the Cybersecurity Review Measures. DCC reads the announcement against the Measures themselves. The review is an Article 16 own-motion proceeding initiated by the working mechanism and cleared by the Central Cyberspace Affairs Commission — not the Article 5 pathway where a CIIO declares a procurement — so there is no applicant, no declared transaction, and the Article 11/14 clocks apply only by analogy. Article 21 puts cybersecurity equipment and cloud computing services squarely in scope; Article 10 supplies the risk factors that a cloud-synchronized firewall estate maps onto almost line by line. The operative question for overseas counsel is not what happens now — nothing does — but what a failed outcome would mean: CIIOs must stop procuring, and CSL Article 37/67 as amended in 2025 exposes a CIIO that keeps using un-passed products to a fine of 1× to 10× the procurement amount plus RMB 10,000–100,000 personally. Non-designated companies acquire no legal obligation at all. Based on commentary from 数据何规, checked against the official announcement and the Micron precedent.

    cybersecurity-review · palo-alto-networks · 派拓
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