More Thoughts on Presidential National Security Memorandum-7

It’s been just under two weeks since West Wing officials on September 25, 2025, uploaded National Security Presidential Memorandum 7 [NSPM-7] on the White House website.

The document’s cryptically vague title is Countering Domestic Terrorism and Organized Political Violence.  If you happen to be an evil homegrown “terrorist” who is roaming America in an escalating rampage of “assassinations and other political violence,” you’re likely on the government’s radar – shutdown or not.

What is not immediately evident, though – (even after wading through the dense text in the 1700-word document) – is who else should be worried. The possible range of individuals, organizations, entities, and “networks” who may have bulls eyes on their backs because of NSPM-7 is breathtaking – and alarming.

Who from the government is involved – and how?  The September 25th Memorandum vividly describes a team of law-enforcement personnel from several agencies including the FBI, the U.S. Marshal’s Service, the DOJ, and the IRS spreading out and assisting the FBI’s National Joint Terrorism Task Force (NJTTF) in “facilitating information and intelligence sharing to prevent and respond to terrorist threats.”

They will have the power and authority to  uncover and interrogate, arrest and prosecute, or at least disrupt or dismantle targets of interest.

Mentioned, or at least suggested, as possibly within this crowded field are the nation’s “non-profit entities” including officers and board members, supporters, and funders.

First Thoughts

Last week, in Administration Targets Charities Aggressively  (September 30, 2025) FPLG Blog, we wrote some first thoughts about this serious development. There were then, and continue to be, many uncertainties about the meaning and scope of the September 25th Memorandum. But two points are coming more sharply into focus day by day.

First, NSPM 7  stands out as a “break the glass” moment in the nation and for the charitable sector particularly. See for example: How Should Funders Respond to an “Existential Threat?”  (September 30, 2025), David Callahan, editor-in-chief, Inside Philanthropy.

In FPLG’s September 30th blog post, we wrote: “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.”

Second, NSPM 7 is a stunning executive-power grab of American philanthropy through fear and intimidation as well as the silencing of dissent. More to the point, the government is stifling unapproved thoughts, policies, and programs.

A hypothetical administration official might privately muse about rewriting the 501(c)(3) definition as “organized and operated exclusively for MAGA purposes….”  (To that point, the federal authors of NSPM-7  offer their own  “profile” of a domestic terrorist: “Common threads animating this violent conduct include 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.”)

More Documents

In September 30th’s FPLG blog post – Administration Targets Charities Aggressively – there are a few links to government documents related to NSPM-7.

The Fact Sheet (September 25, 2025) posted on the White House website is one such document. But it’s little more than a summary of the full NSPM-7 which “establish[es] a comprehensive strategy to investigate, disrupt, and dismantle all stages of organized political violence and domestic terrorism.”

Since then, Attorney General Pam Bondi has released her own explanations and further (quite scary) instructions, particularly with regard to opposition to current activities of ICE. See Attorney General Memorandum (September 29, 2025). Her Memorandum is addressed to the directors of the FBI, the US. Marshal’s Service, the Executive Office of U.S. Attorneys, the DEA Administrator and a few other federal offices.

Mentioning almost each and every new act of opposition to the deployment of ICE personnel in U.S. cities, the Attorney General has authorized and encouraged more and harsher action and tactics against protestors. “Enough is enough. The Department of Justice will stand strong when federal law enforcement officers are attacked or threatened for doing their sworn duty on behalf of the  United States government.”

Additional Expert Analyses

The links in last week’s blog post to commentary by professional experts continue to be helpful in understanding the meaning and application of NSPM 7 .

Check out these additional selections:

• Presidential Memorandum on Countering Domestic Terrorism: Legal and Enforcement Implications (October 2, 2025) Ann K. Battle, Esq. & Megan E. Bell, Esq., et al,  MorganLewis
• Presidential Memorandum Signals Expanded Use of Counterterrorism Tools: Implications for Domestic Organizations and Organizers (October 2, 2025) Client Alert, David A. Newman, Esq. & Brandon L. Van Grack, Esq. et al, MorrisonForster
• RE: Trump Issues Memorandum Directing Law Enforcement to Target “Domestic Terrorism” and “Organized Political Violence” By Nonprofits and Others (September 26, 2025) Katherine LaBeau, Esq., et al, Elias Law Group LLP
• Why it Matters: The Escalated and Unwarranted Targeting of the Nonprofit Sector (September 25, 2025) Shannon McCracken, President & CEO, The Nonprofit Alliance
• ‘Stakes Are High:’ Big Law Alerts Clients on Trump’s Domestic Terrorism on Order (October 3, 2025) Jacob Knutson, democracydocket.com

Conclusion

Among the topics coming up are strategies for the charitable sector to thwart and defend against unconstitutional and overbroad government intrusions.

There’s been quite a bit of activity already in this regard, but much more is needed.

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