New DOJ guidance helps companies understand their obligations under the DSP, which could severely impact investment agreements and ordinary commercial data transactions.
On April 11, 2025, the US Department of Justice (DOJ) released new guidance on its final rule, known as the “Data Security Program” (DSP), which went into effect on April 8, 2025. The DSP prevents foreign access to sensitive US data, which includes bulk sensitive personal data and government-related data (“covered data”). The guidance includes a Compliance Guide, extensive FAQs, and an Implementation and Enforcement Policy, resulting in a package of explanatory guidance materials to spur attention and compliance with the DSP.
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