Connect with the right partners. Strengthen your program. Export compliance doesn’t have to be overwhelming, especially when you know where to turn for help. This session features Star USA’s president Michael D. Easton alongside Nate Ward from the SBDC Export…
DOJ: New Data Security Program Enforcement Reshapes U.S. Data Handling Obligations
DOJ: New Data Security Program Enforcement Reshapes U.S. Data Handling Obligations
January 2, 2026/
The Department of Justice’s Data Security Program (DSP) is now fully in force, significantly expanding U.S. government oversight of how sensitive personal and government-related data is collected, shared, and accessed—particularly where foreign entities are involved. Effective October 6, 2025, the DSP introduces sweeping restrictions that go beyond traditional data privacy frameworks, capturing a wide range of commercial, operational, and technical activities that may expose U.S. data to foreign persons or governments.
The rules apply broadly to U.S. companies, individuals, and organizations that handle bulk sensitive personal data or government-related information, including data that is anonymized, encrypted, or otherwise de-identified. Notably, the DSP can reach routine business practices that are not typically considered “data transfers,” such as the use of third-party advertising technologies, analytics tools, or embedded software that enables downstream access to data. With civil and criminal penalties now on the table, organizations should reassess their data flows, vendor relationships, and compliance programs to account for the DSP’s expansive scope and enforcement posture.
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