Overview
This white paper was originally published on May 21, 2025 and has been updated to reflect developments as of October 10, 2025. Enforcement of the Data Security Program (DSP) began in July 2025, and no enforcement actions have yet been announced as of October 2025.
The US Department of Justice (DOJ) recently announced that it will begin enforcement of sweeping new rules regarding the transfer and storage of sensitive US data in July 2025. The rules prohibit transfers of sensitive personal data and US government-related data to certain countries of concern and persons affiliated with those countries, either directly or indirectly. Violations of the rules can result in significant civil or criminal penalties for individuals and companies. The new rules also mandate certain due diligence and auditing requirements, as well as contractual language when engaging in data transactions with any foreign party.
This white paper provides a detailed analysis of the newly enacted regulations, including the types of transactions they prohibit or restrict, and outlines the necessary actions that corporations and individuals must take to ensure compliance with these rules.
A full copy of the white paper is available for download here.
