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

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 new guidance on its final rule, known as the “Data Security Program” (DSP), which went into effect on April 8, 2025. The DSP…