DOJ emphasizes need to come into full compliance with its new rule by July 8.

By Jennifer Archie, Heather B. Deixler, Clayton Northouse, Michael Rubin, Max Mazzelli, Brianna Gordon, and Kiara Vaughn

On April 11, 2025, the US Department of Justice (DOJ) released guidance regarding its final rule, known as the “Data Security Program” (DSP). The DSP, originally issued on December 27, 2024, and effective on April 8, 2025 (with certain diligence, auditing, and

New DOJ guidance helps companies understand their obligations under the DSP, which
could severely impact investment agreements and ordinary commercial data transactions.

By Jennifer ArchieHeather B. DeixlerClayton NorthouseMichael RubinMax MazzelliBrianna Gordon, and Kiara Vaughn

On April 11, 2025, the US Department of Justice (DOJ) released new guidance on its final rule, known as the “Data Security Program” (DSP), which went into effect on April 8, 2025. The DSP