What Is NSPM-7? Domestic Terrorism Memo, IRS Role, Civil Liberties

NSPM-7 is a National Security Presidential Memorandum signed on September 25, 2025, titled “Countering Domestic Terrorism and Organized Political Violence.” It directs the Joint Terrorism Task Forces, the Department of Justice, the Department of the Treasury, and the IRS to investigate, prosecute, and financially disrupt individuals and organizations engaged in politically motivated violence.¹ The memorandum was issued three days after a separate executive order designating Antifa as a domestic terrorist organization, and it lays out the investigative and enforcement framework federal agencies must follow to act on that designation.²

What the Memorandum Directs Agencies to Do

NSPM-7 puts the National Joint Terrorism Task Force and its local field offices at the center of the enforcement strategy. The JTTFs are told to coordinate a “comprehensive national strategy to investigate, prosecute, and disrupt entities and individuals” involved in politically motivated violence, and to give regular progress updates to the President through the Homeland Security Advisor.¹ This shifts the JTTFs onto ground they have not historically occupied. Their traditional focus has been international terrorism and foreign-directed plots.

The memorandum frames politically motivated violence broadly, describing it as acts of intimidation “designed to suppress lawful political activity or obstruct the rule of law.” It also authorizes the Attorney General to recommend that additional groups whose members meet the federal statutory definition of domestic terrorism be designated as domestic terrorist organizations, so the Antifa designation is not necessarily the only one that will follow.

Who and What Gets Investigated

The memorandum casts a wide net. Three categories of targets stand out:

Federal crimes related to recruiting or radicalizing people for political violence, terrorism, conspiracy against rights, or the violent deprivation of any citizen’s rights.
Institutional and individual funders, officers, and employees of organizations that sponsor or assist the people carrying out the violence.
Nonprofits and U.S. citizens abroad with ties to foreign governments or influence networks who may be violating the Foreign Agents Registration Act or laundering money to support domestic terrorism.

The Attorney General’s December 2025 implementation guidance lists the conduct that should be treated as a domestic terrorism priority: organized doxing campaigns, swatting, rioting, looting, trespass, assault, destruction of property, threats of violence, and civil disorder.³ The memorandum also requires federal law enforcement agencies with investigative authority to interrogate individuals engaged in political violence about who organized the actions and who paid for them before any plea agreement is reached.

Financial Disruption and the IRS Role

A large part of NSPM-7 is about cutting off money. The Secretary of the Treasury, working through the Terrorism and Financial Intelligence office, is directed to deploy investigative tools, examine financial flows, and trace illicit funding streams in coordination with other agencies.¹

Separately, the IRS Commissioner is told to ensure that no tax-exempt organizations are financing political violence or domestic terrorism, directly or indirectly. Where the IRS finds such activity, it must refer the organizations and their leadership to the Department of Justice for investigation and potential prosecution.¹ This IRS directive has drawn particular scrutiny because federal law already makes it a felony for senior officials to direct politically motivated tax investigations, creating a tension between the memorandum’s instructions and existing statutory guardrails.

How the Attorney General Is Implementing It

The Attorney General’s December 2025 guidance translated the memorandum’s broad directives into concrete timelines. All federal law enforcement agencies were told to turn over any Antifa-related intelligence to the FBI within 14 days for review by the JTTFs.³ The FBI was also directed to reopen matters from the previous five years that may have involved domestic terrorism, using all available tools to identify participants, organizers, and financial sponsors.

Other deadlines in the guidance:

The FBI has 30 days to establish recommendations for publicizing its tip line and to update its Digital Media Tipline capabilities.
Within 60 days, the FBI must produce an intelligence bulletin on Antifa and aligned anarchist violent extremist groups.
The FBI must compile a list of groups whose activities may meet the statutory definition of domestic terrorism and deliver that list to the Deputy Attorney General.
The FBI files initial reports within 30 days and updated reports every 30 days thereafter.

A cash reward system was also established for information leading to the arrest of individuals in the leadership of domestic terrorist organizations.³

Civil Liberties Concerns

NSPM-7 has drawn sharp criticism from civil liberties organizations. The most fundamental objection is constitutional. Congress has never created a domestic terrorist organization designation regime, in large part because any such system risks punishing people for their beliefs and associations rather than criminal conduct. The First Amendment protects political speech, organizing, and protest, and critics argue the memorandum’s vague categories blur the line between protected expression and prosecutable activity.

The memorandum’s own language illustrates the concern. It references ideological categories like “anti-Americanism, anti-capitalism, and anti-Christianity” and opposition to “traditional American views on family, religion, and morality” as indicators of the threat environment. Critics say these are political viewpoints, not criminal acts, and that directing federal law enforcement to investigate based on ideological profiles invites politically motivated enforcement.

The instruction to investigate nonprofit funders and organizational leadership is another flashpoint. Federal agencies already have authority to investigate actual crimes, but the memorandum’s push to proactively scrutinize civil society groups, donors, and NGOs through the JTTF structure goes further than standard criminal investigations. The FARA investigation mandate raises additional concerns because that statute’s terms are broad enough to potentially sweep in journalists, academics, and nonprofits with any ties to foreign entities.

The memorandum contains a standard general provisions clause stating that it must be “implemented consistent with applicable law” and does not create enforceable rights. Whether that language meaningfully constrains the investigative activities the memorandum directs remains an open question that courts may eventually address.

Not to Be Confused With the 2017 NSPM-7

NSPM numbering resets with each presidential administration, so the same number can refer to entirely different directives. In the first Trump administration, NSPM-7 was titled “Integration, Sharing, and Use of National Security Threat Actor Information to Protect Americans” and was dated October 4, 2017. That earlier memorandum dealt with intelligence-sharing about foreign threat actors and has nothing to do with domestic terrorism. Readers looking for the directive that established the National Vetting Center want NSPM-9, signed February 6, 2018, not either NSPM-7.⁴ Searches for “NSPM-7” in 2026 will generally return the current domestic terrorism memorandum.

1
The White House. Countering Domestic Terrorism and Organized Political Violence
2
The White House. Designating Antifa as a Domestic Terrorist Organization
3
U.S. House of Representatives. Office of the Attorney General Guidance on NSPM-7 Implementation
4
The White House. Presidential Memorandum on Optimizing the Use of Federal Government Information in Support of the National Vetting Enterprise