Key Takeaways from the White House’s ‘America First Investment Policy’ Memo

Client Alert
february 24, 2025

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The White House’s America First Investment Policy memorandum (dated Feb. 21, 2025) outlines a set of directives aimed at strengthening domestic industry, securing critical supply chains, and increasing scrutiny of both inbound and outbound investments in strategic sectors.

 

Priority: Supporting Domestic Suppliers

The memo instructs federal agencies to prioritize policies and programs that encourage domestic production and investment, particularly in areas deemed vital to national security and economic resilience, such as healthcare, semiconductors, energy, and defense-related manufacturing. It also emphasizes the need to reduce reliance on high-risk foreign sources, particularly PRC-based entities, and directs agencies to implement procurement and funding policies that favor U.S.-based production and suppliers.

 

The memorandum further signals a more restrictive approach to inbound and outbound investments in sensitive industries. It calls for agencies to assess and enhance existing mechanisms for reviewing foreign investments in the U.S., which could indicate potential expansions in the scope or enforcement of CFIUS review. These include new possible restrictions on “private equity, venture capital, greenfield investments, corporate expansions, and investments in publicly traded securities, from sources including pension funds, university endowments, and other limited-partner investors.” Additionally, the directive lays the policy groundwork for expanded outbound investment restrictions. Similar to the policy recommendations outlined by the House Select Committee on China, the White House memo calls for targeted restrictions on high-risk sectors such as semiconductors, artificial intelligence, quantum, biotechnology, hypersonics, aerospace, advanced manufacturing, directed energy, and other areas implicated by the PRC’s national Military-Civil Fusion strategy.

 

“Industry should view the memorandum as a clear message that the new administration is prioritizing expanded regulations to address supply chain, investment, and critical technology risk.”

Kit Conklin
Exiger SVP of Risk and Compliance

Framework for Supply Chain and Investment Strategies

The memo also outlines key policy recommendations for supply chain security and resilience. For companies that do business with the U.S. government, the memorandum suggests that stricter “Buy American” provisions and compliance requirements may be forthcoming. It also instructs agencies to ensure that federal procurement and funding decisions align with the broader goal of reshoring critical industries and supporting domestic suppliers.

 

While the memo does not establish immediate regulatory changes, it provides a framework for upcoming policy shifts that could affect investment strategies, supply chain planning, and federal contracting. Companies and financial institutions operating in industries affected by these policies should monitor agency-level implementation and consider how increased domestic sourcing requirements or foreign investment restrictions may impact their operations.

1. Prioritization of Domestic Investment & Supply Chain Security

  • Federal agencies are instructed to prioritize domestic production incentives and reshoring efforts in critical industries, including semiconductors, defense, energy, and emerging technologies like AI and quantum computing.
  • This reinforces ongoing U.S. efforts to reduce reliance on China and other geopolitical competitors for critical supply chain inputs.

 

2. Expansion of Foreign Investment Reviews & Restrictions

  • Agencies are directed to enhance scrutiny of foreign investments in sensitive U.S. industries, potentially broadening the scope of CFIUS reviews.
  • The memo suggests a tougher stance on outbound investments to countries deemed national security risks, mirroring recent executive actions on U.S. capital flows to China.

 

3. New Compliance & Procurement Standards for Government Contractors

  • Companies seeking federal contracts or funding may need to comply with new domestic sourcing requirements, reshoring mandates, and “Buy American” provisions.
  • This could impact procurement strategies for businesses reliant on foreign suppliers, particularly in defense, energy, and advanced manufacturing.

 

4. Potential Impacts on Global Supply Chains & Investment Strategies

  • Firms engaged in cross-border M&A, venture capital, or private equity — particularly in AI, biotech, and critical minerals — may face new hurdles in structuring transactions.
  • Multinational corporations may need to reassess supply chain vulnerabilities and explore nearshoring or friendshoring strategies.

 

What’s Next?

The memo provides broad directives but lacks immediate regulatory actions. However, agencies such as the Treasury Department (CFIUS), Commerce Department (BIS), and Defense Department are expected to issue detailed implementation rules in the coming months. Companies should proactively assess exposure to U.S. government funding, supply chain dependencies, and foreign investment risks.

 

Exiger will continue monitoring developments and advising clients on compliance, risk mitigation, and investment strategy adjustments. For a deeper dive into how this policy may impact your business, contact our team.

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