---
title: "List an overseas disclosure without applying a cross-border rule"
url: "https://ailawframework.com/obligations/confidentiality-and-client-information/check-a-proposed-overseas-disclosure-of-client-personal-information-agai/united-states"
type: "task_jurisdiction_version"
site: "AI Law Framework"
id: "A51-MA20261022-2-US"
practice_area: "Confidentiality & client information"
tier: "yellow"
lawyer_review: "required"
jurisdictions: ["US"]
last_reviewed: "2026-10-22"
---

# List an overseas disclosure without applying a cross-border rule

> List the country named in the proposal and the categories of client information it would send. Do not say the disclosure is permitted and do not send it.

Canonical page: https://ailawframework.com/obligations/confidentiality-and-client-information/check-a-proposed-overseas-disclosure-of-client-personal-information-agai/united-states  
Last reviewed: 2026-10-22

Site index for agents: https://ailawframework.com/llms.txt

## Key facts

| Fact | Value |
| --- | --- |
| Practice area | [Confidentiality & client information](https://ailawframework.com/obligations/confidentiality-and-client-information.md) |
| Human involvement | Yellow: Lawyer and AI draft together |
| How AI is used | List the country named in the proposal and the categories of client information it would send. Do not say the disclosure is permitted and do not send it. |
| What the lawyer must review | You decide whether it may go. No cross-border privacy rule was opened. Do not apply a foreign principle or invent a contractual clause. Model Rule 1.6(a) and (c) still govern information relating to the representation. If the information is protected health information, 45 CFR § 164.502(a) bars a use or disclosure the subpart does not permit. No section on disclosures outside the United States was opened. Formal Opinion 512 requires informed consent before the information goes into a self-learning tool. The country is the country the proposal names. |
| Written for | United States |
| Applies to | [Check a proposed overseas disclosure of client personal information against APP 8](https://ailawframework.com/obligations/confidentiality-and-client-information/check-a-proposed-overseas-disclosure-of-client-personal-information-agai.md) |

## Checking plan

- What the AI does: List the country named in the proposal and the categories of client information it would send. Do not say the disclosure is permitted and do not send it.
- Basis: Checked against the linked sources on 22 October 2026. Confirm the current instrument before reliance.

## Notes

- Do not treat a cloud vendor's region as a decision that the disclosure is allowed.
- A business-associate contract under § 164.504(e) was not opened.

## Sources

- [ABA Model Rule 1.6, Confidentiality of Information](https://www.americanbar.org/groups/professional_responsibility/publications/model_rules_of_professional_conduct/rule_1_6_confidentiality_of_information/) (checked 2026-10-22)
- [45 CFR § 164.502 (uses and disclosures of protected health information)](https://www.ecfr.gov/current/title-45/subtitle-A/subchapter-C/part-164/subpart-E/section-164.502) (checked 2026-10-22)
- [ABA Formal Opinion 512, Generative Artificial Intelligence Tools (29 July 2024)](https://www.americanbar.org/content/dam/aba/administrative/professional_responsibility/ethics-opinions/aba-formal-opinion-512.pdf) (checked 2026-10-22)

*Practice guidance for planning and review. Confirm current primary sources and the requirements of the actual matter. This is general information, not legal advice.*