As of July 8, 2025, DOJ expects full compliance with its Data Security Program (DSP), which implements former President Biden’s Executive Order on Preventing Access to Americans’ Bulk Sensitive Personal Data and United States Government-Related Data by Countries of Concern. To assist organizations in navigating the DSP, this article synthesizes insights shared by Latham & Watkins partners Jennifer Archie and Michael Rubin during a firm program regarding the broad scope of the rules and the key provisions, with a focus on prohibited data brokerage arrangements and restricted vendor agreements. See “Examining DOJ’s Final Rules on Access to Government and Sensitive U.S. Personal Data” (Jan. 29, 2025).