Insights

On February 21, 2025, President Trump issued a National Security Policy Memorandum (“NSPM”) announcing the Administration’s “America First Investment Policy” (the “Investment Policy”)[1] affirming the United States’ commitment to open investment while safeguarding national security. Aimed at promoting investment in the United States from allied countries while imposing stricter measures on both inbound and outbound investments from “foreign adversaries,” the Investment Policy incentivizes foreign investment in the United States by announcing a “fast track” process “to facilitate greater investment from specified allied and partner sources in United States businesses involved with United States advanced technology and other important areas.” The NSPM defines “foreign adversaries” to include the People’s Republic of China (the “PRC” or “China”), including Hong Kong and Macau, Cuba, Iran, North Korea, Russia, and the Maduro regime in Venezuela.[2]

Among the flurry of executive actions taken during his first day in office, President Trump formally established the U.S. Department of Government Efficiency Service (DOGE) via executive order (EO) on January 20, 2025, reconstituting the formerly named U.S. Digital Service that was created in 2014 by President Obama within the Office of Management and Budget. 

On August 20, 2024, the Department of State’s Directorate of Defense Trade Controls (DDTC) published an interim final rule to streamline defense trade between and among Australia, the United Kingdom (UK), and the United States in furtherance of the trilateral security partnership (the “AUKUS” partnership). The interim final rule implements the proposed rule DDTC published on May 1, 2024 with changes and is effective September 1, 2024, though DDTC is seeking comments on or before November 18, 2024.