Florida AG Forms Unit to Combat Foreign Data Threats

JD Supra Trade Law

Published March 4th, 2026

Detected March 5th, 2026

Summary

The Florida Attorney General has established a new unit, the Consumer Harm from International Nefarious Actors (CHINA) Prevention Unit, to investigate and prosecute foreign companies misusing Floridians' personal data. The unit will focus on companies linked to foreign adversaries, particularly in the healthcare sector, and will investigate money laundering and cyber fraud.

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What changed

The Florida Attorney General's office has created a new task force, the CHINA Prevention Unit, to investigate and prosecute foreign companies that misappropriate personal data from Florida residents. This unit will specifically target companies with ties to "foreign adversaries," including those connected to the Chinese Communist Party (CCP), with an initial focus on the healthcare industry due to the sensitivity of data it handles. The unit's scope extends to investigating money laundering, cyber fraud, and other crimes, and it will examine both foreign-domiciled companies and U.S. entities with foreign ownership or data access arrangements.

This initiative represents an expansion of state-level enforcement into areas traditionally handled by federal agencies, such as national security and data privacy concerning foreign influence. Foreign companies operating in Florida, especially those in the healthcare sector or with links to China, face increased scrutiny and potential civil and criminal enforcement actions, even without evidence of data breaches. The unit's formation suggests a more aggressive stance on data protection and national security concerns related to foreign data access, aligning with recent federal actions like Executive Order 14117 and the BIOSECURE Act.

What to do next

Review data handling practices for potential exposure to foreign adversaries, particularly those linked to China.
Assess compliance with Florida consumer protection and criminal statutes regarding data privacy.
Evaluate existing data sharing agreements with foreign-owned or controlled entities.

Penalties

Potential criminal and civil enforcement actions.

Source document (simplified)

March 4, 2026

Florida AG Forms CHINA Unit Focused on Foreign Data Threats

Ashley C. Grabowski, John Korba, Joseph Swanson Foley & Lardner LLP + Follow Contact LinkedIn Facebook X Send Embed

Florida Attorney General (AG) James Uthmeier has announced the creation of a specialized task force dedicated to investigating and prosecuting foreign companies that misappropriate Floridians’ personal data under existing Florida consumer protection and criminal statutes. The Consumer Harm from International Nefarious Actors (CHINA or the Unit) Prevention Unit will specifically focus on companies linked to “foreign adversaries,” including those with connections to the Chinese Communist Party (CCP).

While the unit will primarily focus on the health care industry, which Uthmeier identified as possessing “the most sensitive of human data,” all foreign companies operating in Florida face increased risk in the form of potential criminal and civil enforcement actions. The CHINA Unit will also investigate allegations of money laundering, cyber fraud, and other crimes linked to the CCP and other nations of concern. The health care sector, however, has been considered one of the most susceptible to exploitation in light of the industry’s reliance on Chinese-manufactured medical devices. The CCP’s ability to compel production of data collected by companies subject to its control has long been an identified concern voiced by many in the national security community. The Unit’s focus appears to extend not only to foreign-domiciled companies but also to U.S. entities with foreign ownership, control, or data access arrangements.

Uthmeier’s office has recently initiated investigations into entities spanning a variety of industries, including Shein Marketplace, a Chinese e-commerce platform; Lorex Technology, Inc., a Canadian company that specializes in Wi-Fi security cameras and baby monitors; Contec, a Chinese company that sells Internet-connected medical devices; and TP-Link Systems, Inc., which produces Wi-Fi routers. Public statements indicate that subpoenas and audit letters have already been issued by the Florida AG’s office to companies with known or suspected ties to China. The Unit can be expected to utilize its investigative powers under a wide range of local Florida laws under the jurisdiction of the AG’s office in order to aggressively pursue its stated goals.

The creation of this Unit expands state-level enforcement to issues traditionally reserved for federal regulation, such as national security and foreign influence on data privacy. The Unit’s focus is also consistent with a federal focus on restricting the access to U.S. sensitive data and intellectual property by foreign adversaries for national security reasons. For instance, in April 2025, the Department of Justice’s Data Security Program took effect pursuant to Executive Order 14117, which implements prohibitions and restrictions on transfers of U.S. data to countries of concern, including China. In addition, in December 2025, the BIOSECURE Act became law, which aims to prevent the U.S. government from procuring biotechnology equipment or services from designated biotechnology companies of concern, initially including entities derived from the U.S. Department of Defense’s list of Chinese military companies.

The CHINA Unit’s dual aims of prevention and enforcement present an increased likelihood that foreign companies will face investigative action even absent evidence of data breaches or security failures. Accordingly, foreign companies operating in Florida should:

Ensure that privacy policies and other disclosures clearly state whether data is stored on foreign servers or accessible to foreign entities.
Conduct an audit of IT processes and data infrastructure to identify foreign data transfers that would warrant disclosure.
Implement enhanced data protection procedures to ensure compliance with the unit’s security expectations. [View source.]

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.
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Foley & Lardner LLP Contact + Follow Ashley C. Grabowski + Follow John Korba + Follow Joseph Swanson + Follow more less

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