EO 14352Executive OrderTrump 47 · R

Executive Order 14352

Saving TikTok While Protecting National Security

In simple terms

This executive order determines that a proposed divestiture of TikTok's U.S. operations qualifies under the Protecting Americans from Foreign Adversary Controlled Applications Act, creating a new U.S.-based joint venture with less than 20% foreign ownership. The order delays enforcement of the Act for 120 days to allow completion of the transaction, directs the Attorney General to issue protective guidance to providers, amends a 2020 divestment order related to ByteDance's acquisition of Musical.ly, and designates the Attorney General as the government's representative under the Framework Agreement.

Record & deadlines

  1. Signed

    Signed by the President

  2. FR published

    Published in the Federal Register · 90 FR 47219

  3. Attorney General to issue protective letters to providers

  4. Attorney General to issue written guidance implementing subsection (a)

  5. 120-day enforcement delay expires; Attorney General enforcement moratorium ends

Market exposure

Policy exposure mapping — not investment advice. Illustrative public companies are incomplete and not recommendations.

Mechanisms

Ban / prohibitionLicensing

Role pressure

  • ProtectiveDomestic producer — New U.S.-based joint venture majority-owned by U.S. persons gains protected operational status with algorithmic control and data localization requirements
  • AdverseImporter — ByteDance and foreign adversary affiliates reduced to under 20% ownership, lose operational control and data access
  • MixedDownstream manufacturer — App store operators and hosting providers receive 120-day liability shield but face uncertain long-term regulatory environment; dependent on deal completion
  • ProtectiveProject developer — American content creators and businesses retain platform access; new joint venture creates U.S.-based revenue and employment opportunities

Geographies

Exposure dates

  • — 120-day enforcement delay expires; Attorney General enforcement moratorium ends

Illustrative public companies

Curated watchlist matches by sector/role — incomplete; not a recommendation.

MMM3MGOOGLAlphabetAAPLAppleCATCaterpillarFCXFreeport-McMoRanGEVGE VernovaHONHoneywellQQQInvesco QQQ TrustMETAMeta PlatformsMSFTMicrosoftNVDANVIDIAORCLOracleSPYSPDR S&P 500 ETF

Confidence: medium · Policy alerts

Key directives

  • Attorney General shall not enforce the Act for 120 days from September 25, 2025
  • DOJ shall take no action to enforce Act or impose penalties during 120-day period
  • DOJ shall not penalize conduct from January 19, 2025 through end of 120-day period
  • Attorney General shall issue written guidance implementing enforcement delay
  • Attorney General shall issue protective letters to providers confirming no liability
  • Attorney General shall defend Executive's exclusive enforcement authority against state and private action
  • Attorney General or designee shall serve as U.S. Government representative under Framework Agreement
  • Attorney General shall receive information from joint venture and trusted security partners
  • Revoke Presidential Memorandum of July 24, 2024
  • Amend August 14, 2020 Divestment Order sections 2(b), 2(g), and strike sections 2(d), 2(e)

Who is ordered

Prior policyRollback

  • revokePresidential Memorandum of July 24, 2024 (Delegation of Authority Under the Protecting Americans from Foreign Adversary Controlled Applications Act)
  • amendOrder of August 14, 2020 (Regarding the Acquisition of Musical.ly by ByteDance Ltd.)
  • otherSections 2(d), 2(e) of August 14, 2020 Divestment Order

Related orders

What to expect

Immediate

  • 120-day enforcement delay takes effect
  • Attorney General directed to issue guidance and protective letters to providers
  • Presidential Memorandum of July 24, 2024 revoked
  • Divestment Order amended

Near term (90d)

  • Attorney General to issue written guidance (Sec. 3(b))
  • Attorney General to issue protective letters to providers (Sec. 3(c))
  • Framework Agreement implementation agreements to be executed

Long term

  • Completion of qualified divestiture transaction
  • CFIUS agreement with Investor Parties to ensure alignment of economic incentives with national security compliance
  • Ongoing monitoring of algorithms, software updates, and data flows by trusted security partners
  • Retraining and monitoring of recommendation models using U.S. user data

Risks & tensions

  • Framework Agreement implementation agreements not yet executed at time of order—divestiture remains contingent
  • 20% foreign ownership cap leaves residual foreign influence risk; monitoring regime untested
  • State and private enforcement preemption claim (Sec. 3(d)) may provoke legal challenges
  • CFIUS agreement with Investor Parties still pending; order assumes future execution
  • Order explicitly reserves presidential authority for further action, suggesting conditional satisfaction with deal
  • ByteDance operational relationship prohibition relies on self-executing contract terms and monitoring, not statutory mandate
Executive Order 14352: Saving TikTok While Protecting National Security · Executive Orders