Administration Targets Charities Aggressively

The full array of outrageous, bizarre, and norm-breaking presidential directives since Inauguration Day 2025 pales in comparison to the orders from the Oval Office last week.

From Monday through Friday – September 22nd through 26th – the administration took aim at what it characterizes – (absent any basis in truth) – as the hotbed of training in political violence that is (much of) the U.S. charitable community. Most particularly chilling is Thursday’s National Security Presidential Memorandum 7 (September 25, 2025).

Titled Countering Domestic Terrorism and Organized Political Violence, NSPM-7 is a full assault on the nation’s 501(c)(3) organizations as well as their “officers and employees,” “institutional and individual funders,” and “supporters” as well as anyone who “aids and abets” them. Helps them out, how? Assists in allegedly “… fomenting radical and dangerous views and conduct reflecting ‘anti-Americanism, anti-capitalism, and anti-Christianity; support for the overthrow of the United States Government; extremism on migration, race, and gender; and hostility towards those who hold traditional American views on family, religion, and morality…”

See also, the companion Fact Sheet: President Donald J. Trump Develops New Strategy to Counter Domestic Terrorism and Organized Political Violence (September 25, 2025) “Today, President Donald J. Trump signed a National Security Presidential Memorandum (NSPM) establishing a comprehensive strategy to investigate, disrupt, and dismantle all stages of organized political violence and domestic terrorism.”

This is a ten-alarm-fire, infringing as it does on the complete range of rights guaranteed under the First Amendment: freedom of thought, speech, and expression; freedom of association, to “peaceably assemble,” and to “petition for redress of grievances”;  freedom against “the establishment of religion, or prohibiting the free exercise thereof,” and – surely also – freedom of the press. Reporters can be expected – encouraged even! – to write about the civil and criminal sanctions pursued by officials with gusto.

Baseless Investigations

The week had opened on Monday with the president Designating Antifa as a Domestic Terrorist Organization (September 22, 2025). Not only is there no such thing as a “domestic terrorist organization,” Antifa “is just short for anti-fascist”; that is, “the opposition to fascism.”

By Friday, it was clear that federal officials, under the president’s direction, were on a full-speed-ahead course of criminal prosecution of “political enemies.” Justice Dept. Official Pushes Prosecutors to Investigate George Soros’s Foundation (September 25, 2025) Devlin Barrett, The New York Times.

See also news of the indictment of former FBI Director, James Comey. Although neither a liberal nor the head of a charitable organization, Comey had opposed the president or his policies. Suddenly, he was a “bad person,” a “sick person,” earning himself a spot on the “enemies” list.

Dangerous Times for Charities

The administration asserts that the beliefs enumerated in the September 25th Memorandum including “anti-Americanism, anti-capitalism, and anti-Christianity” have “…’animat[ed]’ political violence.” Turning Powerful Post 9-11 Counterterrorism Tools Onto Domestic Policy Targets (September 26, 2025) Deborah A. Curtis, et al, Arnold & Porter. Officials seek to create a government-wide effort to “investigate and disrupt networks, entities, and organizations that foment political violence.”

By the “plain terms” of the Presidential Memorandum, even the “indirect” financing of “political violence” could have consequences for these organizations.” This “… sweeping National Security Memorandum transforms the risk landscape for U.S. tax-exempt organizations and their funders.””

See also: Presidential Memorandum on Political Violence Raises Questions Regarding Next Steps for Foundations and Other Nonprofits (September 26, 2025) Client Alert, Lauren N. Moore, Esq., et al, WilmerHale. “President Trump issued a memorandum on September 25, 2025, directing a national strategy to counter domestic terrorism and political violence, with a specific focus on nonprofit organizations, funders, and foundations.”

“The directive authorizes federal agencies—including the DOJ, FBI, Treasury, and IRS—to investigate, prosecute, and financially scrutinize individuals and organizations allegedly involved in political violence, including through tax-exempt status reviews and criminal enforcement.”

The Wilmer Hale experts warn that “[n]onprofit organizations, especially those associated with progressive causes, may face increased scrutiny, including IRS investigations, terrorism designations, and asset freezes targeting both the organizations and their officers.”

Conclusion

Amidst the deluge of other news of significance including the government shutdown, this presidential directive is important enough to merit diligent and continued attention.

See, for example, Statement from Diane Yentel on Reported Trump Administration Criminal Investigations Targeting Nonprofits (September 25, 2025): “Let’s be very clear: baseless criminal and civil investigations into nonprofits are not about preventing violence–they are about silencing organizations and individuals with which the administration disagrees …. Those making these accusations have presented no evidence linking 501(c)(3) organizations to acts of recent political violence. Such rhetoric and actions undermine the lifesaving work of millions of nonprofit staff and volunteers and puts them at risk. We condemn both political violence and the reckless targeting of nonprofits.”

– Linda J. Rosenthal, J.D., FPLG Information & Research Director