Russia Data Localization Update: Results from Regulatory Inspections Clarify Enforcement Approach
Roskomnadzor has been conducting compliance inspections both according to the plan and in individual cases when it has reason to do so. The results of those inspections and recent comments by the Head of Roskomnadzor, Mr. Zharov, all yield insights into the regulatory expectations and the risk of noncompliance with the data localization law. In an interview, Mr. Zharov, announced that Roskomnadzor has found most of the companies that it has inspected this year to be compliant with the data localization requirement. In particular, he commented that out of 645 inspections, Roskomnadzor has found only four violations of the data localization requirement. While it is clear that the regulators still expect Russian personal data to be stored in Russia, companies may have more of a grace period to cure instances of noncompliance than originally expected, so long as they are making a good faith effort to comply.