S5E2: Redrawing Data Lines - DOJ’s DSP and the New National Security Mandate
Your “encrypted” data may still be regulated and today the rules start to bite. We unpack how the Department of Justice’s Data Security Program moves from guidance to strict enforcement and why it reframes data governance as a national security mandate. From redefining “covered data” to treating anonymized and encrypted datasets as in-scope when they enable linkage or inference, we walk through what changes right now for risk leaders, counsel, and compliance teams.
We detail the two buckets that matter: prohibited transfers that stop cold, and restricted transfers that demand verifiable, ongoing controls. You’ll hear how the rule targets six countries of concern, China, Russia, Iran, North Korea, Cuba, and Venezuela, and why your contracts, audits, and vendor oversight must reach beyond first-line providers into sub-processors and hidden supply-chain links. We share a practical playbook: deep data mapping across systems and shadow IT, tiered vendor due diligence that verifies beneficial ownership and jurisdictional exposure, and contract clauses that add audit rights, localization, and explicit DSP obligations. Training becomes the connective tissue so sales, procurement, and operations can spot and halt restricted transactions before they happen.
Zooming out, we connect compliance to resilience. Treat this as a defense capability: build architectures that segment sensitive data, constrain cross-border flows, and maintain auditable trails. Prepare for forced decoupling scenarios with diversified providers and kill-switches. The hard question we leave you with: how many tiers deep should your due diligence go to prove control under this new national security lens? Press play to learn the steps to take today, and the mindset shift that will keep you both compliant and resilient. If this was useful, follow the show, share it with your team, and leave a review so more leaders can find it.
Podcast Episode Chapters
0:46 - Enforcement Day: What Changes Now
2:01 - Covered Data Redefined
3:34 - Encrypted Data Still Counts
4:48 - Countries of Concern and Risk Scope
5:37 - Prohibited vs Restricted Transfers
7:35 - Proof, Audits, and Paper Trails
8:53 - Three Immediate Actions
10:43 - Vendor Chains and Contract Overhauls
11:49 - Training and Consequences
12:53 - From Compliance to Resilience
13:38 - The New Geopolitical Mandate
14:08 - How Deep Must Due Diligence Go?
Don't forget to subscribe on your favorite podcast platform—whether it's Apple Podcasts, Spotify, or Amazon Music.
Please contact us directly at info@wheelhouseadvisors.com or feel free to connect with us on LinkedIn and X.com.
Visit www.therisktechjournal.com to learn more about the topics discussed in today's episode.
