Data, Trade & Cross-Border Flows: Trends in the Middle East and North Africa Region

It is now widely acknowledged that the regulation of personal data is structured around
three dominant regulatory models—often described as competing “data realms”
(Aaronson and Leblond, 2018), “digital empires” (Bradford, 2020) or “digital kingdoms”
(Gao, 2023). These are commonly associated with the European Union’s comprehensive
and rights-based regulatory approach, China’s approach emphasising data sovereignty
and national security, and the United States’ market-oriented model. Each model reflects
distinct political, industrial, and trade policy objectives (Dimitropoulos, 2025).
These dynamics are closely linked to broader debates about the future of the open
internet, particularly the extent to which cross-border data flows (CBDFs) can be
sustained in an increasingly fragmented regulatory environment. Against this backdrop,
the interplay between trade and data governance in the Arab countries of the Middle East
and North Africa (MENA) region has received comparatively limited scholarly attention.
Patterns in domestic data laws governing CBDFs across the region, alongside evolving
approaches within Preferential Trade Agreements (PTAs), illustrate how states navigate
the tension between openness and control. In this context, CBDFs are not only a matter
of trade but also a determinant of whether digital ecosystems remain interconnected or
become more territorially segmented. These developments can therefore be understood
in relation to the wider global landscape shaped by the three dominant models of data
governance and digital trade.