Accurate classifications today. Fewer surprises tomorrow. Classification errors can result in unexpected duty costs, compliance risks, and increased scrutiny. Join Michael D. Easton of Star USA, to learn when product classifications should be reviewed, how to identify common risk areas,…
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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