Steptoe White Paper: DOJ Set To Begin Enforcement Of New Data Security Program

Executive Summary

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, authored by members of our National Security, Data Privacy, and WhiteCollar practices, 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