Addressing Risks From Susman Godfrey
The order directs federal agencies to suspend security clearances for Susman Godfrey LLP employees, terminate federal contracts involving the firm, restrict its staff's access to government buildings, and require contractors to disclose any business relationships with the firm.
It is one in a series of orders targeting specific law firms the Administration accuses of undermining national security, election integrity, and federal anti-discrimination priorities.
What this order does
What it orders
The order directs federal agencies to take several immediate actions against Susman Godfrey LLP. The Attorney General, Director of National Intelligence, and all relevant agency heads must suspend any active security clearances held by Susman employees pending a national-interest review. The Office of Management and Budget must identify all government property, services, and facilities provided for the firm's benefit, and agencies must cease providing them to the extent the law allows. Government contracting agencies must require contractors to disclose any business relationships with Susman, and agency heads must review all contracts involving the firm and move to terminate those where Susman performs services. Agencies must also limit Susman employees' physical access to federal buildings and restrict official government engagement with them. Agency officials are barred from hiring Susman employees without a waiver.
The order explicitly preserves actions authorized under a prior order targeting Perkins Coie LLP regarding racial discrimination, signaling it operates within a broader framework of similar directives. All actions are conditioned on "to the extent permitted by law," and the order contains standard severability and no-private-right-of-action clauses.
Who it affects
Susman Godfrey LLP and its employees, who face suspended security clearances, restricted federal building access, and a hiring freeze across agencies. Federal contractors who do business with Susman must now disclose that relationship. Federal agencies across the executive branch are directed to review and restructure contracts and access policies.
Why it matters
A major private law firm loses access to federal contracts, government facilities, and classified information unless agencies grant specific waivers. Federal contractors doing business with the firm face heightened scrutiny. The order extends a pattern of executive action using security and contracting levers to restrict specific law firms' access to the federal government.
What must happen and when
How the order is supposed to work
Agencies first suspend Susman employees' security clearances and cut off government-provided facilities, then audit all contracts touching the firm. Each agency submits a contract assessment to the OMB Director within 30 days and begins termination procedures where applicable. Contractors must proactively disclose Susman ties before agencies can flag and review those relationships. Hiring of Susman employees requires a head-of-agency waiver in consultation with the OPM Director. The order's "to the extent permitted by law" hedge on most directives means legal challenges could limit agency actions at each stage.
Actions and deadlines
- Suspend active security clearances held by Susman Godfrey employees pending national-interest review
- Identify all government goods, property, and services provided for the benefit of Susman Godfrey and cease their provision
- Require government contractors to disclose any business they conduct with Susman Godfrey
- Review all contracts with Susman Godfrey or entities disclosing business with the firm and take steps to terminate applicable contracts
- Submit to the OMB Director an assessment of contracts with or related to Susman Godfrey and any actions taken
- Issue guidance limiting Susman Godfrey employees' access to federal government buildings and restricting official government engagement with them