Up until October 2015, Safe Harbor rules had governed EU data flow for about 15 years. After the EU's decision to strike the agreement, U.S. companies involved in international data transfer may face liability or enforcement action if the necessary precautions are not taken. Indeed, Germany has recently indicated that it will investigate global companies that are relying on the defunct Safe Harbor. Meanwhile, the U.S. and European Commission have reached a tentative agreement on a "Privacy Shield" framework to replace the Safe Harbor, but uncertainty remains until this deal is finalized.