Under the Radar: DOJ's Data Security Rules and Their Impact on Payments Companies — Payments Pros – The Payments Law Podcast
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In this episode of Payments Pros, Carlin McCrory is joined by Pete Jeydel, a partner in the firm's White Collar Litigation + Investigations Practice Group, to discuss the new Department of Justice (DOJ) Data Security Program...more
As of July 9, the U.S. Department of Justice has begun full enforcement of a sweeping new data regulation known as the Sensitive Data Rule, or “SDR.” Implemented under President Biden’s Executive Order 14117, the SDR marks a...more
Protecting sensitive data has never been more important. In a globalized world of advanced cyber threats, sophisticated espionage techniques, and external data monetization, increased security is crucial to safeguard...more
The U.S. Department of Justice has added a new weapon to its enforcement arsenal, aimed at enhancing its ability to prevent foreign adversaries from accessing and exploiting government related data and sensitive personal data...more
On July 9, 2025, the Department of Justice (“DOJ”) commenced enforcement of its new Data Security Program (“DSP”) to prevent foreign adversaries from accessing sensitive U.S. data. Created earlier this year, the program seeks...more
On April 8, 2025, the US Department of Justice’s National Security Division’s final rule regulating sensitive data about US persons came into effect. DOJ also announced a 90-day grace period on enforcement. At a moment of...more
On July 8, the DOJ’s National Security Division (NSD) will begin enforcing its Data Security Program according to a notice from April titled “Data Security Program Implementation and Enforcement Policy” which outlined the...more
The US Department of Justice’s (DOJ’s) final rule implementing Executive Order (EO) 14117, Preventing Access to Americans’ Bulk Sensitive Personal Data and United States Government-Related Data by Countries of Concern went...more
The Department of Justice (“DOJ”) implemented the Data Security Program (“DSP”) intending to prevent access to Americans’ bulk sensitive personal data and government-related data by Countries of Concern. The DSP is aimed at...more
The United States Data Security Program (DSP) represents a significant regulatory undertaking by the US government to control the flow of bulk sensitive data to specific foreign countries, for national security purposes....more
On July 8, 2025, the Department of Justice (“DOJ”) is set to lift its self-imposed pause on enforcing certain violations of its Rule Preventing Access to US Sensitive Personal Data and Government-Related Data by Countries of...more
The Department of Justice (DOJ) implemented a new regulatory regime (Data Security Program) addressing access to, and transfer of, sensitive personal data to countries and persons of concern, including Russia, China and...more
Pursuant to a newly effective U.S. Department of Justice (DOJ) regulation, the transfer and storage of certain sensitive U.S. government and personal data may be prohibited or restricted, depending on the intended recipient,...more
If you thought your company's collection of email address, IP address, zip code, birth date, or cookie data was too mundane to catch the federal government's attention – think again. Effective April 8, 2025, a new DOJ final...more
U.S. companies are running out of time to comply with a sweeping new Department of Justice (DOJ) rule that limits sharing sensitive personal data with certain foreign countries—including China, Russia, and Iran. With a hard...more
On April 8, 2025, the Department of Justice’s new rule on Access to U.S. Sensitive Personal Data and Government-Related Data by Countries of Concern or Covered Persons took effect. The rule, referred to by DOJ as the Data...more
A month has passed since the Department of Justice (DOJ) National Security Division’s (NSD) issued its Final Rule prohibiting certain transactions involving US government data and Americans’ bulk sensitive personal data....more
While the US federal government is largely scaling back its rulemaking and compliance efforts, one critical exception is where personal data and technology intersect with national security. Exemplifying this trend, on April...more
On April 11, 2025, the U.S. Department of Justice’s National Security Division (NSD) issued a Compliance Guide to provide additional information to assist companies and individuals in complying with the NSD’s Data Security...more
On January 8, the US Department of Justice (DOJ) issued a final rule under Executive Order 14117, which established the Rule Preventing Access to US Sensitive Personal Data and Government-Related Data by Countries of Concern...more
What's Changed? The U.S. Department of Justice (DOJ) published a Data Security Program (DSP), pursuant to a final rule (Final Rule), which became effective on April 8, 2025....more
On April 11, 2025, the Department of Justice's National Security Division (NSD) issued additional guidance to assist U.S. organizations in understanding and complying with the Data Security Program (DSP). As discussed in our...more
On April 11, the Department of Justice issued an extensive set of FAQs on its Bulk Data Access Rule and advised that it “will not prioritize civil enforcement actions against any person for violations” of the Rule through...more
Many “good government” initiatives continue to be enacted or implemented on Capitol Hill or in the Executive Branch — notwithstanding changes in political control. While working on Capitol Hill, the bulk of the legislative...more
The Data Security Program (DSP) recently implemented by the U.S. Department of Justice (DOJ) will have far-reaching implications for many businesses that transfer the personal data of U.S. citizens outside the United States....more