As set forth in a press release issued on March 31, 2017, Věra Jourová of the European Commission announced that the Privacy Shield will have its first annual review sometime in September.  This press release provides portions of a recent speech given by Ms. Jourová.  And, according to this speech given in Washington, the review “will be an important milestone where we need to check that everything is in place and working well.”

Given that over 2,000 U.S. companies have already committed to Privacy Shield compliance, it is highly unlikely that the EU will disrupt this replacement to Safe Harbor after the September review.   As before, it will likely take a court challenge to rock this crucial agreement for cross-border data flows.