Addressing Risks From Perkins Coie LLP
The order directs immediate suspension of security clearances held by Perkins Coie LLP employees, limits the firm's access to federal buildings, and requires agencies to review and potentially terminate contracts with the firm or any federal contractor that does business with it.
It also directs the EEOC and the Justice Department to investigate large law firms — not just Perkins Coie — for racial and sex-based discrimination under federal civil rights law, making this one of the broadest uses of executive authority to directly target a named private law firm in modern history.
What this order does
What it orders
The order directs the Attorney General, the Director of National Intelligence, and other relevant agency heads to immediately suspend security clearances held by Perkins Coie LLP employees pending a national-interest review. It requires OMB to identify all government goods, property, and services — including secure facilities — being provided for the firm's benefit and directs agencies to cease that provision. Government contracting agencies must require federal contractors to disclose any business they conduct with Perkins Coie, and agency heads must review all contracts connected to the firm, taking steps to terminate them to the maximum extent permitted by law. Agency officials are also directed to limit Perkins Coie employees' access to federal buildings and to refrain from hiring them without a waiver.
Separately, the order directs the EEOC Chair to review hiring and promotion practices at large and influential law firms for compliance with Title VII of the Civil Rights Act of 1964, and directs the Attorney General — in coordination with the EEOC and state attorneys general — to investigate those firms for race- and sex-based discrimination. All agencies must submit a contract assessment to the OMB Director within 30 days of signing.
Who it affects
Perkins Coie LLP, its individual attorneys and staff holding security clearances, federal agencies and contractors that currently employ or do business with the firm, and large law firms broadly subject to EEOC and Justice Department review of their diversity hiring practices.
Why it matters
Perkins Coie employees with active security clearances face immediate suspension and potential permanent revocation. Federal agencies and contractors doing business with the firm face contract termination reviews. Large law firms industry-wide face a new federal investigation into diversity hiring practices, creating legal and reputational risk across the profession.
What must happen and when
How the order is supposed to work
The order runs on parallel tracks: security clearances are suspended immediately by the AG and DNI; OMB simultaneously audits services flowing to the firm and orders their cutoff. Contracting agencies layer in a disclosure requirement — contractors must identify Perkins Coie ties, then agencies review and potentially terminate those contracts. A hard 30-day deadline requires all agencies to report their contract assessments to the OMB Director. The EEOC and AG investigation of large law firms runs on a separate, open-ended track with no stated deadline. Waivers for hiring former Perkins Coie employees require agency-head approval in consultation with OPM.
Actions and deadlines
- Immediately suspend security clearances held by Perkins Coie employees pending a national-interest review
- Identify all government goods, property, and services provided to Perkins Coie and cease their provision
- Require federal contractors to disclose business relationships with Perkins Coie
- Review and take steps to terminate contracts with Perkins Coie or contractors doing business with the firm
- Submit to the OMB Director an assessment of contracts with or connected to Perkins Coie and any actions taken
- EEOC Chair to review large law firms' hiring and promotion practices for Title VII compliance
- Attorney General to investigate large law firms doing business with federal entities for civil rights violations
- Provide guidance limiting Perkins Coie employee access to federal buildings and official government engagement