Most firms keep their files with Microsoft, Google or Dropbox. All three are American companies, and for a law firm that is a legal fact before it is a technical one.
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Where the data sits does not decide who can demand it.
The US CLOUD Act lets American authorities compel a US provider to hand over data in its possession, custody or control, wherever in the world it is stored.1 A data centre in Frankfurt or Dublin does not change who controls it.
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Foreign clients’ data is the explicit target.
Section 702 of FISA allows US intelligence agencies to require US providers to give access to the communications of people outside the United States, without an individual warrant.2
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The legal basis has failed twice, and is in court again.
The Court of Justice of the EU struck down Safe Harbor in 2015 and Privacy Shield in 2020, both over US surveillance.3 Their successor, the 2023 Data Privacy Framework, rests on a US executive order and is under appeal before the same court.4
Its oversight is weaker than when it was signed: in June 2026 the US Supreme Court held that the President may remove FTC commissioners at will, and the FTC is one of the bodies the framework relies on.5
For a profession whose first duty is confidentiality, that is a great deal of someone else’s law to rely on.