Addressing Risks From WilmerHale

This executive order targets the law firm WilmerHale, directing federal agencies to suspend security clearances held by its personnel, cease provision of government facilities and services, require contractor disclosure of business with the firm, review and terminate contracts where legally permissible, limit official access to federal buildings, and restrict hiring of WilmerHale employees without waivers. The order cites the firm's pro bono work, its hiring of former Mueller investigation prosecutors, and alleged racial discrimination as justifications.

Federal Register Open PDF 90 FR 14549

Impact dates

Apr 26, 2025
Agencies submit contract assessment with WilmerHale to OMB

Key directives

Suspend active security clearances held by WilmerHale individuals pending review
Identify and cease provision of government goods, property, and services to WilmerHale
Require government contractors to disclose business with WilmerHale
Review and terminate contracts with WilmerHale where legally permissible
Limit official access of WilmerHale employees to federal buildings
Restrict hiring of WilmerHale employees without agency head waiver and OPM consultation
Align agency funding decisions with Administration goals and EO 14147

Who is ordered

Timeline

Immediate

Suspension of active security clearances for WilmerHale individuals
Identification of government goods/services provided to WilmerHale
Cessation of provision of government materials and SCIF access

Near term (90d)

Contractor disclosure requirements implementation
Agency contract reviews and termination actions
30-day deadline for agencies to submit contract assessments to OMB
Guidance on building access and official engagement limitations

Long term

Potential lasting restrictions on law firm access to federal government
Precedent for targeting specific private law firms with executive action
Possible litigation challenging order's legality

Risks & tensions

First Amendment and due process concerns from targeting a specific private law firm by name
Potential abuse of executive power for political retaliation against legal adversaries
Legal challenge risk under Fifth Amendment takings clause and Bill of Attainder concerns
Vague 'interests of the United States' standard creates discretionary uncertainty for agencies
Contractor disclosure requirement may chill attorney-client relationships and legal representation
Cross-reference to EO 14230 on Perkins Coie suggests pattern of targeting specific law firms
Security clearance suspension without individualized adjudication may violate procedural norms