Addressing Risks From WilmerHale
The order directs the immediate suspension of security clearances held by WilmerHale attorneys, restricts the firm's physical access to federal buildings, bars agencies from engaging with the firm officially, and requires agencies to review and potentially terminate contracts involving the firm.
It is part of a broader series of executive orders targeting major law firms the administration views as adversarial, and uses security-clearance and contracting mechanisms to limit a private law firm's ability to operate within the federal government sphere.
What this order does
What it orders
The order directs the Attorney General and the Director of National Intelligence to immediately suspend any active security clearances held by WilmerHale employees, pending a review of whether those clearances are consistent with the national interest. It directs OMB to identify all government goods, property, and services provided to the firm and instructs agencies to cease that provision. Contracting agencies must require federal contractors to disclose any business they conduct with WilmerHale, and agency heads must review all contracts involving the firm with a view toward terminating them to the maximum extent permitted by law.
The order additionally limits WilmerHale employees' physical access to federal buildings, restricts government employees from engaging with the firm in an official capacity, and prohibits agencies from hiring WilmerHale employees without a waiver approved by the agency head in consultation with the OPM Director. Agencies must submit a written assessment of their WilmerHale contracts to the OMB Director within 30 days of signing. Throughout, directives are qualified by the phrase "to the extent permitted by law."
Who it affects
WilmerHale attorneys who hold active federal security clearances, federal agencies and contractors that do business with or provide services to the firm, clients of WilmerHale whose contracts involve government work, and government employees whose official interactions with the firm are now restricted.
Why it matters
WilmerHale attorneys lose active security clearances immediately pending review, cutting off the firm's capacity to handle classified legal work. Federal clients face contract reviews and potential terminations, and the firm's employees cannot enter federal buildings or be hired by agencies without special waivers.
What must happen and when
How the order is supposed to work
Agency heads are the primary actors: each must issue internal guidance on access restrictions, conduct contract reviews, and submit a 30-day compliance report to OMB. The security clearance suspension is the most immediately self-executing provision, triggered without any further rulemaking. Contract termination authority is conditioned throughout by "to the extent permitted by law" and the Federal Acquisition Regulation, preserving legal constraints on unilateral cancellation. The 30-day reporting deadline to OMB creates a centralized accountability checkpoint. Waiver authority for hiring sits with agency heads consulting the OPM Director.
Actions and deadlines
- Immediately suspend active security clearances held by WilmerHale employees pending national interest review
- Identify all government goods, property, and services provided to WilmerHale
- Cease provision of government goods and services to WilmerHale
- Require federal contractors to disclose any business conducted with WilmerHale
- Review all contracts with WilmerHale or entities disclosing business with the firm and take termination steps where permitted
- Submit to OMB Director an assessment of WilmerHale-related contracts and actions taken under this order