Independent Audit & Compliance Assessment for Executive Order 14117
The DOJ’s Data Security Program is now in full enforcement. Organizations handling bulk sensitive personal data need more than an internal review; they need defensible, independent validation. Elevate Consult delivers structured audit assessments that stand up to regulatory scrutiny.
What EO 14117 requires from your organization
Executive Order 14117 (paired with the DOJ’s implementing final rule, effective April 8, 2025) establishes a framework to prevent foreign adversaries from accessing bulk sensitive personal data (BSPD), including biometric, genomic, health, geolocation, and financial records, through commercial and governmental channels. The Order targets data flows through “covered transactions” involving countries of concern: China, Cuba, Iran, North Korea, Russia, and Venezuela.
For organizations subject to the rule, compliance is not optional. Violations carry civil penalties and, for willful violations, criminal exposure up to $1,000,000 in fines and 20 years imprisonment. Full enforcement is active. The grace period has expired.
Apr 8
Rule effective date (enforcement active; audit requirement grace period ended October 2025)
10 years
Mandatory document retention requirement
Annual
Independent audit cadence for restricted transactions
6
Countries of concern under the rule
Built for the teams accountable for data security compliance
This service is designed for organizations that collect, process, or transmit bulk sensitive personal data and have existing or potential relationships with vendors, contractors, or partners in countries of concern.
CISOs and Security Leaders
CTOs and AI/ML Leads
Compliance and Risk Officers
Legal and Regulatory Counsel
Board-Level Oversight Functions
Data Governance Leads
Four things we formally validate
Elevate’s independent assessment provides formal validation across the four compliance requirements the DOJ will examine during enforcement review.
System and data flow identification
All in-scope systems, platforms, and data environments have been correctly enumerated and mapped.
Covered transaction restriction
Prohibited and restricted transactions have been identified, classified, and properly secured or terminated.
Technical and administrative controls
Required CISA security requirements — organizational, system-level, and data-level — are designed and operating effectively.
Governance and program sustainability
A formal Data Compliance Program is in place, documented, and capable of sustaining ongoing compliance over time.
A three-phase audit methodology
Every engagement follows a structured, evidence-based approach that validates both design effectiveness and operating effectiveness across all applicable controls. This is not a checklist review; it is an independent audit built to produce a defensible attestation.
PHASE 1
Scoping and rationale evaluation
Validates the “what” and “where” of the organization’s data landscape before any control testing begins.
- System identification across cloud, on-premises, and third-party environments
- Service mapping and vendor agreement review with focus on countries of concern
- Threshold evaluation by data type per DOJ guidance
- Covered transaction classification: brokerage, vendor, and employment arrangements
PHASE 2
Technical security requirements
Tests against CISA Security Requirements to evaluate whether controls are designed and operating effectively.
- Organizational controls: policies, asset inventory, information security function, MFA, incident response, continuous monitoring
- Vendor agreement and provisioning controls
- Data controls: minimization, masking, retention, deletion, and encryption
- Data Compliance Program adherence and documentation review
PHASE 3
Reporting
Draft reports are reviewed with your team before issuance. No findings are final without your input.
- Request list and interview coordination with applicable stakeholders
- Draft review period before final report issuance
- Executive summary for Board and C-suite consumption
- Detailed findings with remediation recommendations
- Management response incorporated into final report
Three structured outputs, built for two audiences
Every engagement produces a complete, documented audit record designed to serve both executive leadership and technical teams, and to meet the DOJ’s evidence and retention requirements.
Executive summary report
Overall compliance posture, key risk areas, and headline findings. Structured for Board, C-suite, and senior compliance leadership.
Detailed findings report
Control-by-control observations, identified risks, supporting evidence, and specific remediation recommendations for each requirement tested.
Supporting workplan
Control matrix with test procedures, results, and evidence listings used to support all audit conclusions.
A formal attestation you can stand behind
Where required by the DOJ framework, Elevate Consult issues a formal auditor attestation confirming the effectiveness, or identifying the limitations, of your implemented controls. This attestation constitutes a regulatory deliverable.
Auditor certification
Independent attestation of control effectiveness or limitations, issued accurately and without qualification. Accuracy and independence are non-negotiable — false or misleading attestations carry significant federal exposure.
Retention-ready documentation
All workpapers, evidence files, and final reports are structured to meet the DOJ’s 5-year retention requirement, with tamper-evident storage, version history, and documented chain of custody.
Common questions
Does EO 14117 apply to my organization if we're not a data broker?
Yes. The rule applies to any U.S. person or entity engaged in vendor agreements, employment arrangements, or investment agreements that could expose bulk sensitive personal data to countries of concern. Organizations in healthcare, finance, technology, and life sciences are routinely in scope — even if they do not sell data commercially.
Is an independent audit legally required under the rule?
For organizations engaged in restricted transactions, annual audits are a compliance requirement under Subpart J of the DOJ final rule. These requirements became enforceable on October 6, 2025. An independent assessment also strengthens your defensibility posture in the event of an enforcement inquiry.
What data types trigger in-scope obligations?
Covered data categories include genomic data, biometric identifiers, precise geolocation, personal health data, personal financial data, and certain government-related data. Volume thresholds vary by data type — our scoping phase validates whether your data meets applicable thresholds.
How long does the assessment take?
Engagement timelines vary based on organizational complexity, the number of covered systems, and the maturity of your existing Data Compliance Program. We scope timeline and effort during the initial discovery call before any engagement begins.
GET STARTED
Ready to validate your EO 14117 compliance posture?
Whether you’re preparing for your first audit, responding to an enforcement inquiry, or building an annual compliance program, Elevate Consult provides the independent assessment your organization needs.