One of the defining attributes of Donald Trump’s second term as President of the United States has been the absolute deluge of words and actions meant to deliberately overwhelm, distract, and disorient potential opponents, and discourage dissent. This is hardly new though, and shouldn’t surprise anyone who stays engaged with politics and other issues affecting our society. 

During Trump’s first term, I actually asked a conservative thought-leader to explain what was going on, and they answered simply, and quite proudly, 

“Smoke on the water.” 

I was aghast. How could someone who so clearly considered themselves a patriot, and had spent their entire career in the military, rising to the rank of Colonel in the Air Force, boast about something so plainly undemocratic? 

Even the word choice was chilling. Maybe they hadn’t consciously considered it, but the use of combat terminology clearly implied that the administration thought of itself as being at war with the population it was elected to serve. Over the years, their words have echoed in my head as a warning. 

Trump’s first-term efforts to obfuscate the administration’s true intentions seem almost quaint by comparison to what’s going on today. I believe that one of the most effective ways to gain clarity in confusing times is to zoom out, and examine the situation in its entirety, rather than fixate on individual cases. It’s only when the “whole board” is visible that trends and strategies begin to emerge. It’s the best way I know of to truly see the forest through the trees.

And so, with that goal in mind, we present to you, a comprehensive list of actions taken during the second Trump administration that we believe might directly or indirectly impact the social impact sector, the philanthropic entities, nonprofit organizations, and individual leaders working within it. We’ll do our best to keep this list updated as new information becomes available, and we invite comments, discussion, additions, and criticism of this list. Please email us at impact@altruous.org if you’d like to contribute.

Mike Spear

Founder & CEO, Altruous.org

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Pre-Inauguration: The Trump Campaign and its Allies’ Forecasting of Events to Come

Spring 2022:

The Heritage Foundation, then a relatively obscure conservative think tank, unknown to most Americans, begins convening conservative organizations to plan for the 2024 election. They gather ideas, build consensus, and begin laying the groundwork for how the conservative movement would position itself during the 2024 presidential election, and how to steer policy during the next conservative administration. Despite its large influence in conservative political circles, roughly 94% of Americans would have been unable to identify The Heritage Foundation by name. The general public had virtually no awareness of the project’s existence, objectives, or scope. 

Spring 2023:

The Heritage Foundation publishes the 920-page document, “Mandate for Leadership: The Conservative Promise,” and begins vetting potential political appointees for the next conservative administration. The document represents the work of more than 400 conservative scholars and policy experts from over 100 conservative organizations across the conservative movement.

Among its many policy positions and authoritarian stratagems, the document describes dozens of plans, policies, and specific recommendations meant specifically to limit the power of the impact sector, including:

• Calls for “aggressive enforcement” of prohibitions on political activity by nonprofit organizations

• Recommendations for reviewing and revoking tax-exemptions for organizations engaged in “partisan” activities

• Guidelines for an expedited revocation process and limited appeal options

• Expansion of the term “political activity,” to include issue advocacy. 

• Proposals for new reporting requirements that increase the reporting burden and compliance costs for nonprofit organizations

• Specific policy and structural changes to be made to the Department of Justice, Department of Education and other cultural, environmental, and healthcare agencies and organizations in order to defund, restrict, make liable for prosecution, or eliminate groups that promote ideas and programming that run counter to the narrative and goals of Project 2025 and the Trump Administration

Fall 2024:

The Trump Administration's sweeping actions against the nonprofit sector in 2025 were extensively foreshadowed during the 2024 campaign and rooted in policies attempted during his first presidency (2017-2021). During the campaign, Trump made eliminating DEI programs a centerpiece of his platform, promising on "Day One" to end all federal diversity initiatives and cut funding to organizations promoting what he termed "radical gender ideology." His campaign spent over $20 million on anti-transgender advertising alone, with slogans like "Kamala is for they/them. President Trump is for you." 

At rallies, Trump consistently promised to ban transgender athletes from women's sports, eliminate gender-affirming care, and recognize only two biological sexes. His "Agenda 47" platform explicitly targeted nonprofits, promising to investigate organizations for "illegal discrimination" and cut funding to any groups supporting immigrants, LGBTQ+ rights, or environmental causes.

These promises built on actions from his first term, including the 2017 transgender military ban, the original Mexico City Policy restricting reproductive health funding, attempted cuts to foreign aid and USAID, and efforts to eliminate federal DEI programs that courts ultimately blocked. Trump's first administration also attempted to merge USAID with the State Department and repeatedly proposed dramatic cuts to social services, arts funding, and scientific research—efforts largely thwarted by Congress and the courts. 

The 2024 campaign rhetoric escalated significantly, with Trump calling immigrants "invaders" who would "cut your throat" and falsely claiming children were being forced into gender reassignment surgery at schools. His promise to conduct "the largest deportation operation in American history" and to use the military domestically represented a dramatic expansion of first-term immigration policies. By January 2025, these campaign promises had crystallized into what Trump himself called a "mandate" to remake American government and society.

Post-Election Transition (November 2024 - January 2025)

The transition plan meticulously prepared by Trump allies springs into action - not just in working on staffing strategies and executive orders, but pushing new legislation through congress that paves the way for future administration orders and activities impacting the nonprofit sector.

November 21, 2024 

The Republican-led House passed legislation that would enable the U.S. Treasury Department to revoke the tax-exempt status of nonprofit organizations that it claims support terrorism" without requiring evidence. Impact of Trump's Election on the Nonprofit Sector | Lumsden McCormick CPA

December 11, 2024

"Trump's election and pressure from conservative activists are leading some of the biggest players in corporate America and higher education to drop or trim their DEI policies" Axios - Trump's election win spurs anti-DEI investments 

Inauguration and Beyond

Once in power the administration begins a maximum pressure campaign (often described as maximum “muzzle velocity”) intended to overwhelm and confuse any potential opposition. A litany of executive orders, memos, and policy changes are implemented at a feverish pace. The administration counts on the fact that their administration can move faster than congress or the courts can respond, ensuring their actions will have lasting impact regardless of potential pushback, legislative guardrails, or judicial determinations of legality that may come later.

January 20, 2025 - Inauguration Day Actions

1. Executive Order: "Ending Radical and Wasteful Government DEI Programs and Preferencing," directing:

• Termination of all DEI programs in government and their associated funding. DEIA office employees placed on administrative leave.

• Federal agencies to identify up to 9 potential civil investigations of large nonprofits, foundations with $500M+ assets, and universities with $1B+ endowments

• Immediate cessation of grants supporting DEI initiatives. Organizations focused on racial equity, gender equity, or providing DEI training services face immediate funding cuts and potential civil compliance investigations.

Administration Statement: Trump declared that the Biden Administration had forced "illegal and immoral discrimination programs" into "virtually all aspects of the Federal Government, in areas ranging from airline safety to the military."

2. Executive Order: "Defending Women from Gender Ideology Extremism and Restoring Biological Truth to the Federal Government"

• All funding for organizations providing gender-affirming care or promoting “gender ideology” is cut

• New federal policy recognizing only two biological sexes is established

• LGBTQ+ service organizations and those providing gender-affirming care face loss of federal funding

Administration Statement: Trump promised at rallies to "ask Congress to pass a bill stating that the U.S. will only recognize two genders as determined at birth" and vowed to "get transgender insanity out of our schools."

3. Executive Order: "Protecting the American People Against Invasion"

• Prioritizes immigration enforcement, allows ICE arrests in sensitive locations (churches, schools, hospitals)

• Mandates 90-day pause on foreign development assistance

• International NGOs and organizations involved in global health/development face immediate funding suspension

• Domestic organizations serving immigrant populations face increased scrutiny, potential funding loss, and exposure to penalties if perceived as facilitating unauthorized immigration

Administration Statement: At campaign rallies, Trump claimed immigrants would "walk in your kitchen, they'll cut your throat" and promised to "demolish the foreign drug cartels, crush gang violence, and lock up violent offenders." Trump states, "the United States is no longer going to blindly dole out money with no return for the American people."

4. Presidential Memorandum: Federal Hiring Freeze

• Freezes all federal civilian employee hiring

• Slows IRS processing of tax-exempt applications, delays responses to inquiries, limits federal agency communications

Administration Statement: Trump promised to "dismantle government bureaucracy" and reduce the federal workforce by 75%.

5. Executive Order: "Initial Rescissions of Harmful Executive Orders"

• Rescinds numerous Biden-era executive orders including those supporting arts, humanities, museums, and libraries as "essential to democracy"

• Cultural institutions lose federal integration into economic development strategies

Administration Statement: Trump promised to reverse "every radical Biden policy" on his first day in office.

January 21, 2025

Executive Order: "Ending Illegal Discrimination and Restoring Merit-Based Opportunity"

• Directs Attorney General to identify private sector companies with "egregious" DEI programs

• Names large nonprofit organizations and educational institutions as eligible for civil compliance investigations

Administration Statement: Trump promised to "immediately stop all federal government efforts to socially engineer race and gender into every aspect of public and private life."

January 22, 2025

The Office of Personnel Management begins implementing the executive orders. It orders the immediate termination of all federal DEIA contractors, and requires agencies to identify any efforts to “disguise” DEI programs using coded or imprecise language. Nonprofit organizations contracted to provide DEI services immediately lose contracts.

January 24, 2025

Reinstated Mexico City Policy through memorandum, stating: "no U.S. taxpayer money supports foreign organizations that perform or actively promote abortion." The policy prohibits U.S. funding of foreign NGOs that provide or promote abortion services. International health organizations must choose between U.S. funding and providing comprehensive reproductive health services.

January 27, 2025

OMB issues Memo M-25-13 ordering temporary pause of all federal grants and loans. The memo targets funding for "foreign aid, nongovernmental organizations, DEI, woke gender ideology, and the green new deal." The memo specifically affects: 

• $3 trillion in federal assistance programs

• Organizations serving immigrants, promoting DEI, environmental causes, or reproductive health

• Directive to review all grants for alignment with administration priorities

Thousands of nonprofits immediately lose access to funding portals; organizations forced to furlough staff or cease operations. They begin to fight back. Multiple lawsuits are filed, and federal judges issue restraining orders blocking implementation.

January 28-29, 2025

The OMB "Rescinds" Funding Freeze Memo, but maintains that executive orders on funding reviews "remain in full force and effect." White House Press Secretary Karoline Leavitt states the rescission was "NOT a rescission of the federal funding freeze" but merely compliance with court order. Chaos and uncertainty continues across the sector as many organizations are still unable to access promised funding. Prospect of constitutional crisis arises, as administration effectively decides to ignore the court order and proceed as originally planned.

February 5, 2025

1. Executive Order 14201: "Keeping Men Out of Women's Sports"

• Bans transgender women and girls from female sports at all educational levels

• Threatens to revoke federal funding from schools that allow transgender participation

• Youth sports organizations, educational nonprofits must comply or lose federal funding

Administration Statement: Trump declared "With this executive order, the war on women's sports is over" and warned schools: "If you let men take over women's sports teams or invade your locker rooms, you will be investigated for 

2. Attorney General Memorandum on DEI Enforcement

• DOJ Civil Rights Division directed to investigate and eliminate "illegal DEI preferences" in private sector

• Report due March 1 identifying "most egregious DEI practitioners"

• Racial and gender equity organizations face increased legal scrutiny

Administration Statement: AG Pam Bondi stated the DOJ "will investigate, eliminate and penalize illegal DEI and DEIA preferences, mandates, policies, programs and activities in the private sector."

February 6, 2025

Presidential Memorandum: "Advancing United States Interests When Funding NGOs"

• Directs all agencies to review NGO funding and align with administration priorities

• Nonprofit whose mission doesn't align with administration goals are immediately threatened

Administration Statement: Trump declared "Many NGOs are engaged in actions that actively undermine the security, prosperity, and safety of the American people. It is the policy of my Administration to stop funding NGOs that undermine the national interest."

February 7, 2025

1. NIH Guidance: Indirect Cost Rate Caps

• Limits indirect cost rates for research grants to 15%

• Research organizations and universities face significant funding shortfalls

Administration Statement: The administration said it would prioritize awards to institutions with "lower indirect cost rates" to ensure taxpayer dollars go directly to research.

2. USAID Shutdown Announcement

• Administration announces plan to dismantle USAID and merge functions into State Department

• International development organizations lose primary funding source, and face prospect of having to conduct mass layoffs.

Administration Statements: Trump called USAID "run by a bunch of radical lunatics, and we're getting them out." Elon Musk declared "USAID is a criminal organization. Time for it to die."

February 10, 2025

Federal Court Grants Preliminary Injunction Against Funding Freeze

• Judge rules administration must restore frozen funding

• Nonprofits receive temporary relief, but administration continues seeking workarounds

• Prospect of constitutional crisis escalates, as the administration looks for ways to ignore, circumvent, or contradict court orders

• The Chan Zuckerberg Initiative announces it will discontinue funding social advocacy work and reassign DEI staff (February 28).

Administration Response: Trump administration immediately appealed, with officials claiming judges were engaging in "judicial activism" and "undermining the President's mandate."

February 19, 2025

Executive Order: "Preserving Federal Benefits for American Citizens"

• Directs agencies to identify and eliminate benefits to undocumented immigrants

• Targets "sanctuary" jurisdictions

• Nonprofit Organizations serving mixed-status families or providing immigrant services face funding cuts

Administration Statement: Trump claimed "American taxpayers spend at least $182 billion annually" on undocumented immigrants and vowed to ensure "Federal funds to states and localities will not be used to support 'sanctuary' policies."

February 25, 2025

State Department Visa Ban on Transgender Athletes

• Bans transgender athletes from entering U.S. for competitions

• Marks visa applications with tracking codes

• International sports organizations and those hosting competitions are directly affected

Administration Statement: The State Department announced it would mark visa applications with tracking codes and permanently ban anyone listing a gender other than assigned sex for "fraud."

February 26-27, 2025

USAID Mass Terminations

• 92% of USAID grants terminated (approximately 4,100 grants)

• 1,600 employees laid off, remainder placed on leave

• Massive disruption to global health, humanitarian aid, and development programs. 

• NGOs begin laying off workers and terminating programs previously funded by USAID

Administration Statement: Secretary Rubio stated programs were "not aligned with Agency priorities" and continuing them was "not in the national interest."

March 2025 

Ongoing Litigation and Implementation

• Multiple lawsuits challenging various executive orders

• Agencies continue identifying nonprofits for compliance investigations

• State Department formally notifies Congress of USAID reorganization plan (March 28)

Administration Statement: Trump repeatedly attacked judges blocking his orders, calling them "radical activists" and threatening to "look at the court system very strongly."

A Major Turning Point:

By late spring, ,the chilling effect this strategy is meant to create begins to take shape. In a March 10 NonProfitPro report, "85% of nonprofit leaders cited ways in which the political climate is already negatively affecting their organization's work, and 94% believe it is very likely to negatively affect their work in the future." Nonprofit organizations across the country begin taking proactive measures to comply with Trump policies, even before they’re officially required to do so. Notably, The Chan Zuckerberg Initiative is one of the first, announcing in February that they would “discontinue funding social advocacy work and reassign DEI staff." 

The Vera Institute reports: "Recent cuts of over $800 million in Department of Justice grants have affected law enforcement and nonprofits alike, terminating at least $168 million for community safety and violence intervention" 

In total, over 42,000 federal grants to nonprofits and 11,000 contracts were under review, affecting organizations ranging from Meals on Wheels (37% federally funded) to domestic violence shelters (some facing 50% budget cuts). The more than 12 million Americans employed by the nonprofit sector face increased uncertainty about the future of their employment and fear reprisals if they speak out against the administration.

July 1, 2025

USAID Officially Dissolved

• Remaining functions absorbed into State Department

• U.S. foreign aid apparatus is permanently restructured

• In the absence of USAID, humanitarian crises around the world are exacerbated, with millions of dollars worth of food and water aid that had already been paid for and delivered to local warehouses is wasted or destroyed. 

Administration Statement: Secretary Rubio declared "We are reorienting our foreign assistance programs to align directly with what is best for the United States and our citizens."

July 4, 2025

The One Big Beautiful Bill Act (H.R.1) is signed into law

Among the widely-reported expansion to defense and border security funding, and cuts to the social safety net (particularly medicare), several provisions threaten the viability of the nonprofit sector. TL:DR; the Act’s projected impact is one of reduced funding for nonprofits from private donors in addition to government funding, and an increase in demand for services to do the cuts in the social safety net. Learn more…

September 10, 2025

Right-wing political activist, entrepreneur, and media personality is killed. Almost immediately, administration officials begin blaming progressive organizations for inciting violence and renews calls for investigating their tax-exempt status. White House deputy chief of staff claims that nonprofits had created “terrorist networks” that led to Kirk’s murder. 

September 25, 2025

The White House releases National Security Presidential Memorandum/NPSM-7, which officially ties acts of political violence including the murder of Charlie Kirk to “Domestic Terrorist Organizations.” It calls on a National Joint Terrorism Task Force (JTTF) to “coordinate and supervise a comprehensive national strategy to investigate, prosecute, and disrupt entities and individuals engaged in acts of political violence and intimidation designed to suppress lawful political activity or obstruct the rule of law.”

Specifically, it calls on the JTTF to investigate:

(i)   institutional and individual funders, and officers and employees of organizations, that are responsible for, sponsor, or otherwise aid and abet the principal actors engaging in the criminal conduct described in subsections (a) and (b) of this section; and

(ii)  non-governmental organizations and American citizens residing abroad or with close ties to foreign governments, agents, citizens, foundations, or influence networks engaged in violations of the Foreign Agents Registration Act (22 U.S.C. 611 et seq.) or money laundering by funding, creating, or supporting entities that engage in activities that support or encourage domestic terrorism.

Since the administration has already broadened the definition of Domestic Terrorism to include people and organizations that oppose their ideology and political goals, NPSM-7 can be seen as a tool to discourage and punish what they view as political dissent, and represents a threat to nonprofits, their funders, and civil liberties in general.

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Photo by Quintin Gellar