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The executive order applies to all educational institutions that receive federal funding. Must adopt compliant policies.

Likely excluded organizations: (1) Provide services to undocumented immigrants or challenge federal immigration; (2) Groups involved in protests or advocacy that result in repeated violations of state laws;
(3) Entities that provide or advocate for gender-affirming care, especially for minors, might be targeted;
(4) Organizations that engage in activities perceived as promoting illegal discrimination or advocating for radical political change could fall under the exclusion; (5) Faith-based groups whose practices are interpreted as discriminatory or in violation of federal laws may be affected.

Specifically, it authorizes actions such as denial, monitoring, suspension, or termination of an accreditor's recognition if they require institutions to adopt DEI initiatives as part of their accreditation process. Pell / loan eligibility impacted.

Public school resources and funding are redirected to private schools. Budget drain for public schools. • Families may have more choices for their children's education, including access to private or specialized schools that were previously unaffordable. But even with vouchers, the cost of private education may remain cost prohibitive for some families (e.g., transportation).

For families with neurodivergent children—such as those diagnosed with ADHD, autism spectrum disorder, or mood disorders—this executive order could cause IEP delays; parent-consent hurdles, and delays, added scrutiny of prescriptions for medications like methylphenidate (Ritalin), Adderall, and mood stabilizers.

The order affirms NIL agreements, but only if structured in a way that preserves or expands scholarships and athletic opportunities for women and non-revenue sports. In other words, high-revenue athletes may be paid but not at the expense of smaller, less profitable programs. Access to federal monies (e.g., Pell Grants) is the likely enforcement hook.

The Department of Education is directed to issue model policies emphasizing individual misconduct rather than any consideration of a student’s race, disability, or other protected characteristic.

Closure could disrupt the administration of Pell, IDEA, OCR (office of civil rights).

Grant loss if deemed lax; OCR investigations. For instance, Columbia University reportedly had $400 million in federal grants revoked due to alleged failures in addressing antisemitism on campus. The Department of Education's Office for Civil Rights has initiated investigations into multiple universities and most recently demanded that the President of Univ. of Virginia stepdown, and who did step down on June 27, 2025. Some of plaintiffs' arguments include that EO 14161 and EO 14188 criminalize or deport international students and scholars based on protected First Amendment activities (e.g., pro-Palestinian protests). Plaintiffs argue visa revocation and deportation procedures based on political viewpoints violate free speech, equal protection, due process, and are vague and overbroad; status is nationwide TRO has been sought to block enforcement of both EOs against plaintiffs..

Qui-tam & OFAC exposure if SDN (specially-designated nationals) are linked to gifts/contracts.

Possible “Trojan horse” oversight.

Students are now compared and ranked using standardized fitness benchmarks rather than guided by individualized wellness goals. This returns emphasis to physical excellence over universal participation. Proponents say the return promotes physical discipline, national pride, and readiness. Critics argue it may induce stress, shame, and exclusion in students who perform poorly or face physical limitations, potentially undermining the inclusive wellness ethos advanced in 2012

Schools that promote or teach “gender ideology” or “discriminatory equity ideology” risk losing federal funding ; possible misdemeanor/felony charges for "sexual exploitation of a minor" or medical malpractice.

Executive Order 14149 focuses on preventing federal interference with lawful speech in terms of what people can say on various social platforms

Under EO 14158, federal agencies are directed to provide DOGE with full and prompt access to all unclassified agency records, software systems, and IT systems, to the maximum extent consistent with law.

In summary, Executive Order 14265 mandates a series of reforms within specified timeframes to modernize the DoD's acquisition processes, emphasizing speed, flexibility, and the integration of commercial innovations. Top of Form

The FAR and its supplements are extensive; identifying which provisions are non-essential yet still critical for certain operations can be complex. So while the EO sets ambitious goals for procurement reform, achieving these goals remain to be seen.

Abolition of DEI Offices: All DEI offices and related programs within the DoD and the Department of Homeland Security (with respect to the Coast Guard) are to be dismantled. Prohibition of certain theories, such as the promotion or teaching of: "divisive concepts," including race or sex stereotyping and scapegoating. Federal Contractors are not DoD but often work closely with DoD and DHS. If your policies, programs, or even brochures are glaringly out of sync with this EO, it will be conspicuous and might even elicit comment from your Govt. point of contact. DEI policies should be widely inclusive and tethered to providing improved business outcomes, including better goods and services.

Within 30 days, agency heads must review all existing discretionary contracts and grants, prioritizing those involving educational institutions and foreign entities, to identify opportunities for termination, modification, or renegotiation to reduce federal spending.

Agencies are required to ensure that designated federal officials have full and prompt access to all unclassified agency records, data, software systems, and IT systems. Agency heads must rescind or modify existing guidance that hinders the sharing of unclassified information between agencies; and reassess their classification policies to prevent unnecessary restrictions on information sharing.

The EO’s emphasis on “dedication to the furtherance of American ideals” and loyalty to the Executive Branch is effectively screening for ideology or viewpoint, especially when embedded in credentials-based hiring.

Federal contractors do not enjoy the same immunity from suits as the federal government. Discontinuing benefits, including gender-affirming care, for employees, could raise litigation risks.

The order declares that identifying as a gender different from one's assigned sex conflicts with a soldier's commitment to an honorable, truthful, and disciplined lifestyle. It further states that the use of pronouns inconsistent with one's assigned sex compromises the ability of the government to establish high standards for troop readiness, lethality, cohesion, honesty, humility, uniformity, and integrity. So it casts transgender identification as a moral or character failure. While Executive Order 14183 specifically targets military service, its underlying principles may influence federal contractors, especially those providing services to the Department of Defense. Contractors may be expected to align their policies with the order's emphasis on biological sex, potentially affecting workplace practices related to transgender employees.

Executive Order necessitates the sharing of certain payment-related data but includes provisions to ensure that such activities comply with existing privacy protections. The order does not extend its oversight to private financial transactions unrelated to federal disbursements

Key Provisions of EO 14192 require that for every new regulation proposed, federal agencies must identify at least 10 existing regulations for repeal. This is a significant escalation from the previous 2-for-1 policy implemented during President Trump's first term.

EO 14147 mandates a thorough review of federal prosecutorial and enforcement actions taken between January 20, 2021, and January 20, 2025. It could have a chilling effect on future investigations and enforcement actions; or it could indirectly sway federal investigators and enforcement agents to find outcomes consistent with the Executive Branch's view.

Federal contractors with existing long-term contracts supplying paper straws to government agencies with no contract exit clause short of force majeure (typically a very high bar to meet in courts) may be affected by this executive order.

Exported US-AI applications should focus on education, healthcare, and agriculture.

Streamlines environmental reviews by directing agencies to create exemptions expedite build out of data centers.

Executive Order 14148 revokes a vast set of Biden-era policies, particularly those related to DEI, LGBTQ+ rights, climate, and immigration. It defines DEI as antithetical to merit and frames it as a form of ideological favoritism.

Corporations that invested in green technologies relying on these now-revoked incentives should reassess their financial and operational plans accordingly. Also, while EO#14315 does not repeal EV vehicle credits. the One Big Beautiful Bill Act, signed into law July 4, 2025, does eliminate federal EV tax credits. Companies offering employee EV incentive programs or subject to state EV mandates will not be able to take advantage of federal credits after September 2025.

The FCPA remains a valid federal law, and bribery of foreign officials is still illegal. The executive order temporarily halts DOJ enforcement but does not repeal the law. The Securities and Exchange Commission (SEC), which enforces the FCPA's civil provisions, has not been directed to pause its enforcement activities. Therefore, companies may still face civil enforcement actions from the SEC .

Private sector general counsel should be aware of potential increases in religious liberty claims from employees. This may include requests for religious accommodation, objections to certain workplace policies on religious grounds, or claims of religious discrimination.

For corporations with a significant number of employees holding visas from countries identified as high-risk, the executive order presents several challenges:

Agencies impacted (SEC, FTC, CFPB, FEC, DOJ, FERC).

All enjoined; retaliation issues. Some of the injunctions nationwide raising concerns about ongoing enforceability in light of Trump v. CASA Inc. (6-27-25). Corporations should take note in terms of who they take on as clients and/or the nature of services provided if deemed contrary to the Trump Administration objectives.

Requires that any AI systems procured by the federal government must meet a new standard of “ideological neutrality,” defined in part by the rejection of DEI as “one of the most pervasive and destructive of these ideologies.” This EO prohibits AI providers from encoding “partisan or ideological judgments” into model outputs—yet simultaneously establishes anti-DEI and pro-nationalist baselines as the standard for neutrality

Executive Order 14151: Mandated the termination of all DEI-related programs, positions, and contracts within federal agencies, labeling such initiatives as discriminatory. Executive Order 14173: Revoked EO 11246, effectively ending affirmative action requirements for federal contractors, and directed agencies to eliminate DEI programs deemed unlawful. Federal Contractors' certification of "compliance" will be subject to FCA enforcement, and private sector DEI initiatives could face legal challenges if DEI programs are perceived as discriminatory under the new federal framework.

Signals wider rollback; HR audit.

Revocation of EO#14036 does not remove legal restrictions on wage-fixing at the federal or state level, nor does it allow for broad and all-encompassing non-competes. First, wage-fixing remains unlawful under the Sherman Act. EO#14337 merely de-prioritizes enforcement. Second, several state antitrust laws prohibit extensive non-competes at certain job levels, and other states have similar limitations on how restrictive non-competes can be. Finally, even though EO#14337 reduces the priority of enforcement of these labor-related antitrust limitations, the statute of limitations on violations, particularly if the violations are ongoing, could extend beyond the current Trump Administration. So just tread carefully as a General Counsel and/or Head of HR.

This could influence the coverage policies of private insurers, especially those participating in ACA marketplaces or receiving federal funds

The issuance of Executive Orders 14278 and 14281 signifies a federal shift towards promoting employment opportunities based on skills and merit, irrespective of formal educational attainment. Per EO 14278, employers are encouraged to adapt their hiring and compliance practices to align with these new directives, Per EO 14281, federal employers are prohibited from engaging in disparate-impact analysis, and state/private sector employers are encouraged to do the same. Employers are to "promote equal access to employment regardless of whether an applicant has a college education, where appropriate."

Though framed as a public welfare effort, the structure, scope, and language reveal a de facto federal law enforcement regime over the District, enabled through an unprecedented blend of federal prosecutorial authority, security agency coordination, and local law enforcement subordination.

As it pertains to law enforcement, there are none to flag at this time.

DOJ and federal agencies will issue “aggressive policing” best practices to be adopted locally. Agencies may feel pressured to align with federal enforcement styles, potentially displacing reform-oriented models. More training opportunities will be provided, but they may prioritize militarized tactics or federal enforcement priorities over local/community-driven ones. Command staff must assess whether federal training curricula conflict with existing accountability or community policing protocols. Local officials, police chiefs, or sheriffs could become targets of federal prosecution or civil enforcement if they resist DOJ guidance or maintain reform-oriented practices (e.g., limits on use-of-force, sanctuary policies, DEI).

While the EO primarily addresses federal incarceration policy, it calls on the Department of Justice and the Department of Homeland Security to expand coordination with state and local law enforcement agencies for fugitive apprehension and joint task force operations.

The deputization of local law enforcement effectively turns local police into ICE agents. This blurs the line between local policing and federal immigration enforcement. Law enforcement, whether deputized or not, should expect an erosion of community trust in their local police.

Certain crime statistics cited in the EO could not be independently corroborated, including the statement that DC's crime was “highest than all 50 states,” and that DC was one of the “top 20% most dangerous cities in the world.”

Embedded in this EO is the threat of federal and local law enforcement if HUD landlords fail to maintain the premises in sanitary conditions of their buildings AND if they fail to "restrict tenants who engage in criminal activity." The EO states that violations of these HUD provisions will be referred to the AG and federal and local law enforcement. There are D.C. tenant protections against landlords evicting tenants based solely on an arrest or for victims of domestic violence. Nevertheless, the EO calls for referrals to federal and local law enforcement for HUD violations.

FDA will ramp up inspections of foreign manufacturing facilities mandated to supply U.S. markets. Tariffs could significantly increase pricing on imported drugs.

Organizations with initiatives supporting or promoting topics such as, critical race theory, immigration, racial preferences, transgender initiatives, or other social movements deemed progressive will not be funded. Also, NGOs/nonprofits that do receive funding are expected to be able to demonstrate progression toward stated objectives and to reduce their administrative costs.

Qui-tam risk for overbilling

Different countries set prices based on a range of factors—list prices, rebates, negotiated discounts, GDP adjustments, or health-technology assessments—making direct comparisons unreliable. HHS clarified MFN applies only to single-source brand-name drugs without generic competition, further restricting and complicating comparisons. Qui-tam risk for overbilling.

The executive branch possesses certain powers to influence federal agencies and their operations. However, the extent to which it can dictate specific historical narratives is constrained by legal and constitutional considerations.

Less risk of criminal liability for unintentional regulatory missteps; more reliance on civil penalties.

For fast-moving-consumer goods, like many ecommerce goods, USA buyers very likely are the Importers of Record and will be responsible for paying the taxes on the imported goods now that the exemption has been eliminated. Processing times also could be adversely impacted -- i.e., formal customs entries required.

Tit-for-tat escalation risk.

EO# 14298 setting reciprocal tariff rates for China remains unaffected by this EO.

Bashar al-Assad remains a Blocked Party (i.e., SDN), as does his senior Syrian government officials, and individuals and entities tied to human rights abuses, terrorism, and narcotics trafficking. Also, BIS has not yet updated the EAR (i.e., Export Administration Regulations). This means that most exports and reexports to Syria involving US goods still require a special license and remain subject to a general policy of denial. BIS is expected to relax the EAR requirements regarding Syria by Q3'25.

Canada hit back on 13 Mar 2025 with 25 % tariffs on $29.8 B in U.S. goods, pulled U.S. liquor from store shelves, and froze new provincial contracts with American firms—raising costs in autos, agriculture, and energy despite narrow USMCA exemptions.

Higher tariffs on imports from China announced in EO#14257 (April 2025) and EO#14298 (May 2025) are delayed until November 9, 2025.

Implement or update compliance programs to include screening of third-party vendors, drivers, and subcontractors against the SDN List. Legal Consultation: Seek legal advice to understand the full scope of EO 14157 and to ensure that your business operations remain compliant with U.S. laws and regulations.

The trucking industry is currently experiencing a significant shortage of qualified drivers, with estimates indicating a deficit exceeding 80,000 drivers nationwide.

Long-term sourcing shift.

Implications of Imposing Secondary Tariffs EO 14245 is believed to be the first time that the U.S. has imposed “secondary tariffs” on countries' imports for purchasing the initially-tariffed item, in this case, Venezuela Oil.

Despite the tariffs, nearshoring in Mexico remains a viable strategy.

Consumers face higher prices and potential shipping delays, while businesses absorb new import costs and paperwork—prompting firms like Shein and Temu to raise prices and shift logistics closer to U.S. buyers.