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ARTICLE · 17 JULY 2025

DOJ's 90-Day Data Security Compliance Grace Period Is Over: Are You Compliant?

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The U.S. Department of Justice ("DOJ") Data Security Program ("DSP") 90-day enforcement grace period ended as of July 8, 2025.

GlobalPrivacy
Townsend Bourne
Townsend Bourne
Sidney Howe*
Sidney Howe*
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The U.S. Department of Justice ("DOJ") Data Security Program ("DSP") 90-day enforcement grace period ended as of July 8, 2025. While the program became effective April 8, 2025, DOJ implemented a 90-day enforcement grace period until July 8, 2025 for good-faith efforts towards compliance (see our previous blog here). With the expiration of the grace period, the majority of the DSP is now effective and will be enforced.

Background

As a reminder, the DOJ DSP aims to protect Americans' sensitive personal data and certain U.S. Government-related data from foreign adversaries (see our blog here for more details on the rule). Specifically, the program prohibits or restricts "covered data transactions," i.e., any transaction that involves any access by a country of concern (China, Russia, Iran, North Korea, Cuba, and Venezuela) or covered person to any bulk U.S. sensitive personal data or government-related data (as defined in the regulations) and that involves data

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