Yesterday, I began a two-part blog post on preparing to respond to the Department of Justice’s (DOJ) new Data Security Program (DSP), which was released on April 8, 2025. Today, I want to conclude this series by reviewing additional key actions you can take now to prepare for the full effective date of October 6, 2025.
- Set up internal processes for training, audit, and reporting.
The DSP does not just ask for policies; it demands proof of implementation. Your organization must build internal compliance muscle around training, auditing, and reporting specific to DSP obligations. Start with training. Who needs to know what? Procurement teams must understand vendor screening protocols. IT and security teams must recognize DSP risk categories. Legal must know the redlines on cross-border data sharing. Executives must understand their certification responsibilities. Everyone must grasp the stakes: violations carry real-world consequences, including civil penalties and criminal charges.
Next comes auditing. You must create audit plans that review DSP compliance across your data lifecycle, collection, storage, access, processing, sharing, and deletion. These audits should be independent, recurring, and specific to your Data Compliance Program. And don’t forget: if you engage in restricted transactions, you must conduct an audit and submit an annual compliance certification. This is not optional, but mandatory compliance activity is baked into the regulation.
Lastly, establish internal reporting mechanisms. That includes hotlines or portals for employees to report suspected violations and internal systems for escalating rejected transactions to compliance or legal. DSP requires you to report known or suspected breaches within 14 days. This is not a theoretical SLA; failing to meet the timeline is a compliance failure. Build templates, designate responsible officers, and track every report. If your whistleblower program is not integrated with your data governance team, you are already behind the proverbial 8-ball.
Think of this as building a new compliance pillar, just like you did for FCPA or anti-money laundering. It’s not about reinventing the wheel but about embedding DSP-specific requirements into the systems, teams, and culture you already rely on.
- Engage your board and C-suite on DSP requirements. This is national security compliance, not just privacy.
One of the most underappreciated risks in corporate compliance today is the leadership’s assumption that DSP is just an extension of privacy laws. It is decidedly not. This is national security compliance. And that means the board and C-suite must be informed and actively engaged.
Start by educating the board on how the DSP aligns with existing fiduciary duties and oversight obligations. Directors must understand that data exposure to hostile foreign powers could result in enforcement actions, reputational damage, shareholder litigation, and, in some sectors, revocation of government contracts. This could raise the level of a material disclosure risk for public companies.
The C-suite also has new legal responsibilities. Senior officers must sign off on DSP compliance certifications, ensure audits are conducted, and provide adequate resources for risk management. That means CEOs, GCs, and CFOs are personally accountable for implementation, and their failure to act could aggravate an enforcement action. Bring DSP compliance into board audit committee agendas. Create executive-level working groups that include the CISO, Chief Privacy Officer, General Counsel, and Chief Compliance Officer. Produce quarterly dashboards showing compliance metrics, known or suspected violations, audit results, and third-party risk assessments.
Do not make the mistake of treating this like another privacy briefing. Treat it like an FCPA or sanctions discussion, with risk maps, case studies, DOJ priorities, and benchmark expectations, because this is not about theoretical data misuse. It’s about preventing hostile state actors’ strategic exploitation of American data. And that is a matter of national urgency. If your board does not understand this message, it is up to compliance to evangelize the message before regulators do it for you.
- Start building your Data Compliance Program today—October 6, 2025, is not as far off as it seems.
October 6, 2025, may feel like a future problem, but let me assure you that the future is already knocking at your door. The DOJ has given us a roadmap and a runway. What you do with that time will define your compliance posture for years. Don’t treat the DSP as a regulatory cliff. Treat it as a strategic build.
Begin by appointing a DSP compliance lead with data governance and regulatory experience. Next, map your data flows, classify your datasets, and identify your exposure to restricted or prohibited transactions. Use that information to build a risk profile. That’s your foundation.
Then, develop your Data Compliance Program. Create written policies for due diligence, vendor screening, internal reporting, and audit procedures. Set up governance structures, designate accountable officers, and prepare for annual certifications. Do not wait until Q3 to scramble; start embedding controls into your existing compliance infrastructure now.
Use this runway to build muscle memory: conduct tabletop exercises, test your reporting protocols, and audit your readiness. Engage your business units with training, mock scenarios, and real-life case studies. The goal is not just compliance; it is about cultural adoption. You’ve already failed if your people see this as a box-checking exercise. The organizations that will thrive under DSP are the ones that treat this not as a regulatory burden but as an opportunity to lead. Because let’s face it: national security compliance is the new frontier. And October 6, 2025, won’t end this journey. It’s the beginning.
The DSP marks a seismic shift for compliance professionals in the era of data as a national security asset. This is not just another privacy framework but a national security regulation with teeth. U.S. companies must now treat data governance the way they’ve treated anti-bribery compliance or export controls: with rigor, documentation, and executive oversight. That starts with reviewing and aligning privacy policies to DSP-defined risk categories, especially around government-related and bulk-sensitive personal data.
Vendor agreements must be audited for exposure to covered persons or countries of concern and updated with enforceable clauses to prevent prohibited data transfers. Organizations must also build robust internal training, auditing, and reporting systems, with mandatory 14-day reporting windows for violations. Most critically, boards and C-suites must be actively engaged, and this is national security compliance, not just IT hygiene. The clock is ticking, with full enforcement kicking in on October 6, 2025. Compliance professionals have a unique opportunity to lead from the front, building a proactive, risk-based Data Compliance Program that integrates DSP mandates into business operations before DOJ examiners come knocking. The message is clear: Know your data. Know your risks.
Finally, take action before your inaction becomes your liability.
