News & Analysis as of

Data Security Compliance Department of Justice (DOJ)

Eversheds Sutherland (US) LLP

Navigating new compliance requirements for DOJ’s Bulk Data Rule

While the US federal government is largely scaling back its rulemaking and compliance efforts, one critical exception is where personal data and technology intersect with national security. Exemplifying this trend, on April...more

Seward & Kissel LLP

DOJ Implements New Data Security Program: Data Transfer Restrictions with a National Security Focus

Seward & Kissel LLP on

Effective as of April 8, 2025, the National Security Division of the U.S. Department of Justice (DOJ) has implemented a Data Security Program (the DSP) to address national security risks associated with the transfer of...more

Perkins Coie

DOJ’s Bulk Personal Data Rule Becomes Effective–Resources for Compliance

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The new Department of Justice (DOJ) rule governing international transfers of Americans’ information, codified at 28 C.F.R. Part 202, became effective on April 8, 2025....more

ArentFox Schiff

Navigating the DOJ’s New Data Transfer Rule: Implications and Compliance Requirements

ArentFox Schiff on

On January 8, the US Department of Justice (DOJ) issued a final rule under Executive Order 14117, which established the Rule Preventing Access to US Sensitive Personal Data and Government-Related Data by Countries of Concern...more

The Volkov Law Group

Episode 366 -- DOJ Issues Data Security Program Requirements

The Volkov Law Group on

Could your routine data transfers now violate federal law? The DOJ’s new Data Security Program (DSP) targets the flow of U.S. sensitive personal and government data to foreign adversaries — and the clock is ticking. In this...more

Pillsbury Winthrop Shaw Pittman LLP

DOJ Releases Its Data Security Program Compliance Guide

The guide outlines the requirements of a newly implemented Data Security Program designed to prevent China, Russia and other foreign adversaries designated by the U.S. Department of Justice from accessing American’s sensitive...more

The Volkov Law Group

DSP Compliance: DOJ Sets July 8, 2025 Deadline (Part III of III)

The Volkov Law Group on

As if legal and compliance professionals had enough responsibilities on their plates, DOJ dropped another shoe (to join the tariffs, sanctions and export controls, and immigration issues) and upped the stakes for ethics and...more

The Volkov Law Group

DOJ Issues Data Security Program Requirements (Part I of II)

The Volkov Law Group on

Many “good government” initiatives continue to be enacted or implemented on Capitol Hill or in the Executive Branch — notwithstanding changes in political control. While working on Capitol Hill, the bulk of the legislative...more

Sheppard Mullin Richter & Hampton LLP

DOJ Announces 90-Day Grace Period for Companies to Comply with New Data Security Rules on Foreign Adversary Access to U.S....

The U.S. Department of Justice (DOJ)’s new data security rule went into effect April 8, 2025. The rule creates what are effectively export controls and requires companies to take measures to prevent U.S. sensitive personal...more

Davis Wright Tremaine LLP

DOJ Issues Guidance on Foreign Data Access Rule, Announces Conditional 90-Day Enforcement Pause for "Good Faith Efforts"

The Department of Justice (DOJ) has issued guidance on its recently effective rule targeting foreign adversaries that "use commercial activities to access, exploit, and weaponize U.S. Government-related data and Americans'...more

Mayer Brown

Department of Justice Releases Compliance & Enforcement Guidance on Data Security Program

Mayer Brown on

On April 11, 2025, the Department of Justice (DOJ) announced additional guidance regarding the implementation of the Final Rule (the “Rule”), Provisions Pertaining to Preventing Access to U.S. Sensitive Personal Data and...more

Foley & Lardner LLP

The More Things Change… DOJ’s Latest Cyber Settlement Shows Continued False Claims Act Risk

Foley & Lardner LLP on

Although the change in administrations has heralded shifting enforcement priorities at the U.S. Department of Justice (DOJ), cybersecurity enforcement under the False Claims Act (FCA) appears to be alive and well. That is the...more

Akin Gump Strauss Hauer & Feld LLP

Security Requirements and Compliance Obligations in DOJ's Final Rule on Data Transactions

The Department of Justice’s (DOJ) final rule implements President Biden’s Executive Order 14117 of February 28, 2024, on “Preventing Access to Americans’ Bulk Sensitive Personal Data and United States Government-Related Data...more

Akin Gump Strauss Hauer & Feld LLP

DOJ Regulations Will Restrict Data Transactions to Address National Security Concerns

The Department of Justice’s (DOJ) final rule implements President Biden’s Executive Order 14117 of February 28, 2024, on “Preventing Access to Americans’ Bulk Sensitive Personal Data and United States Government-Related Data...more

Bradley Arant Boult Cummings LLP

Looking Back at the False Claims Act in 2024 as the Government Keeps its Sights on Cybersecurity in 2025

In 2024, the government and whistleblowers were party to 558 settlements and judgments collecting over $2.9 billion. The government continued its effort to combat cybersecurity threats through its Civil Cyber-Fraud...more

Davis Wright Tremaine LLP

Analyzing President Biden's Ambitious Cybersecurity Executive Order

In his final days in office, President Biden signed an ambitious executive order to improve the federal government's approach to cybersecurity. Executive Order 14114 ("Executive Order"), issued January 16, 2025, titled...more

Sheppard Mullin Richter & Hampton LLP

Data, Deals, and Diplomacy, Part III: DOJ Issues National Security Final Rule with New Data Compliance Obligations for...

On January 8, 2025, the Department of Justice (“DOJ”) published its final rule addressing Executive Order (E.O.) 14117, “Preventing Access to Americans’ Bulk Sensitive Personal Data and United States Government-Related Data...more

Perkins Coie

DOJ’s Final Rule on Data Transfers: Impacts Across Industries

Perkins Coie on

As of January 23, 2025, the regulation discussed below has not been withdrawn by the Trump administration and is not subject to automatic withdrawal under President Trump’s Executive Order freezing regulations. It currently...more

Akin Gump Strauss Hauer & Feld LLP

Holding Former Government Officials Accountable for Election Interference and Improper Disclosure of Sensitive Government...

The Order directs the revocation of any active or current security clearances held by former intelligence officials who worked with former President Biden on his 2020 presidential campaign and several specific individuals....more

Venable LLP

DOJ Issues Final Rule on Bulk Sensitive Personal Data

Venable LLP on

On January 8, 2025, the Department of Justice (DOJ) published in the Federal Register a Final Rule, "Preventing Access to U.S. Sensitive Personal Data and Government Related Data by Countries of Concern or Covered Persons,"...more

Mintz - Health Care Viewpoints

EnforceMintz — Healing Healthcare? DOJ’s Cybersecurity Enforcement Trained Up for 2025

In 2024, the Department of Justice (DOJ) pursued significant enforcement activity under its Civil Cyber-Fraud Initiative (CCFI). As our readers know, the Deputy Attorney General announced the creation of the CCFI in October...more

A&O Shearman

DOJ/CISA finalize new rules regarding data transfers to countries of concern

A&O Shearman on

On December 27, 2024, the U.S. Department of Justice (DOJ) announced its final rule on the transfer of certain bulk sensitive personal data to China, Russia, and other countries. Following this, on January 3, 2025, the U.S....more

Ropes & Gray LLP

DOJ Issues Final Rule Restricting Flow of Bulk Sensitive Personal Data to China and Other Countries of Concern

Ropes & Gray LLP on

On January 8, 2025, the Department of Justice (“DOJ”) published its Final Rule to implement President Biden’s Executive Order 14117, “Preventing Access to Americans’ Bulk Sensitive Personal Data and United States...more

Benesch

Mixed Messages: The Salt Typhoon Encryption Debacle

Benesch on

While the balance of security, privacy, and public safety has always been a concern, recent cyberattacks have highlighted conflicting guidance by United States government officials, creating potential pitfalls for businesses....more

Hinch Newman LLP

DOJ Issues Rule Addressing Threat Posed by Foreign Adversaries’ Access to Americans’ Sensitive Personal Data

Hinch Newman LLP on

On Friday, December 27, 2024, the Justice Department issued a final rule to address “urgent national security risks posed by access to U.S. sensitive personal and government-related data from countries of concern and covered...more

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