The 2025 US National Security Strategy (NSS) [1] catalyzes a policy reset centering on “America First” and realist principles. US policy now squarely rejects multilateralism and constraints from transnational institutions. It prioritizes sovereignty, security in core regions, using policy and tariff leverage to drive reindustrialization, and industrial policy to drive US leadership in critical technologies. In practice, this means quicker, more unilateral US action on sanctions and tech controls; interest-aligned, transactional economic cooperation with allies; and a tighter inbound/outbound investment security framework aimed at capability denial and industrial policy goals. For businesses and investors, the result is greater volatility and friction across borders for technology, sensitive data, goods, people, and capital. In this article we lay out the policy implications of the NSS for transnational companies, investors, and advisors.

The NSS Reset

• Primacy of nations and sovereignty over transnational institutions. The NSS affirms nation‑state supremacy and pledges that the US will chart its own course, signaling less inclination to subsume policy within institutional consensus frameworks or multilateral processes when they are viewed as diluting US interests. 
  Expect more unilateral listings, license conditions, and secondary measures—design change‑in‑law and suspension clauses and maintain rerouting playbooks to preserve continuity.
• Burden‑sharing and burden‑shifting. The NSS conditions deeper cooperation on allies’ alignment with US defense spending and export controls, framing incentives (technology sharing, procurement preferences) for those who match US asks. This introduces explicit regulatory conditionality for transatlantic coordination. 
  Structure commercial and JV arrangements to align with US asks (defense spend, export alignment) to access incentives (technology access, procurement preferences).
• Economic security equals national security. [2] US priorities include balanced trade, tariffs, reindustrialization, supply‑chain control, energy dominance, and standards leadership in AI/biotech/quantum. 
  Scenario‑plan near‑/re‑shoring to Western Hemisphere nodes and model tariff/trade remedy exposure for bill of materials and customer pricing.
• Standards leadership in critical tech. The NSS aims to ensure US technology and standards “drive the world,” positioning the US to export a “full‑stack” AI ecosystem backed by industrial policy, [3] security‑by‑design expectations, and enforcement. 
  Pre‑build security‑by‑design controls aligned to NIST and export conditions to accelerate authorizations and deployments.

Business and Investment Takeaways

• Faster, more unilateral US action on technology and investment security: Expect accelerated export controls and enforcement, tighter end-use/end-user assurance, and built in “security by design” expectations for AI/HPC exports and procurements, with trusted partner incentives and oversight. [4]
• Investment and data perimeters will tighten: Overlapping authorities (CFIUS and related national security agreements, outbound investment diligence, and sensitive data/infrastructure controls) will increasingly shape deal feasibility, structure, and timelines.
• Enhanced diligence becomes baseline: [5] Extraterritorial rules and sector specific controls for advanced computing require deeper technology lineage tracing, end-use validation, supply chain/third party assurance, and audit-grade documentation.

Sanctions, Export Enforcement, and Supply Chains 

• Enforcement-driven choke points: Expect enforcement-driven choke points in advanced compute and other critical technologies, including FDPR-following obligations to track US-origin technology and content across global chains.
• Continuous monitoring: Companies and investors should implement continuous monitoring for list/designation changes, red-flag frameworks, and forensic transaction testing in higher-risk channels.
  • Extend beyond counterparties to technology provenance and downstream end use; integrate FDPR analysis into supplier and product assessments; stand up forensic transaction testing and global site reviews for higher‑risk flows.
  • Programmatically manage red flags and third‑country transshipment risk; maintain audit‑grade records and remediation trails.

Technology Controls and “Security by Design”

• Industrial policy tools: The US will use these tools to promote and accelerate export of the US AI “full stack” to trusted partners while preventing diversion to strategic competitors through policy and financial incentives, integrated security and compliance requirements, and escalated enforcement.
• Compliance controls: Companies and investors should build dual‑track compliance for AI/HPC and critical technology ecosystems and implement auditable assurance controls.
  • Map controls to export license conditions and NIST benchmarks; [6] implement identity/access governance, geo‑blocking, usage controls, and secured data pipelines; and prepare for ongoing oversight/reporting expectations.
  • Architect layered defenses across physical, network, compute, storage, application, and monitoring, with scalable pathways for operational growth. 

Investment Screening and Mitigation

• Use of CFIUS‑style tools will remain central: [7] We expect to see an increased emphasis on early risk analysis and lifecycle mitigation—technology control plans, independent monitorships/audits, data segregation, and reporting obligations.
• Time-to-close and post‑close obligations will increase: Transaction value and structure should account for mitigation costs and operational segmentation.
  • Run prefiling risk assessments early to shape structure and mitigation; plan for non‑US screening interplay and build timing/cost buffers; anticipate technology control plans and reporting. 

Data Protection and the US Data Security Program (DSP)

• Sensitive data is treated as a national security asset: [8] Programs must harmonize regulated-data requirements and define a hardened, auditable “regulated data environment” with clear trust boundaries, continuous monitoring, and an authorization/assurance case. [9]
• Practical implementation elements include:
  • Data classification and boundary definition across sensitive data types and relevant access controls and governance
  • Increased expectations regarding training and insider threat programs, zero‑trust architectures, encryption at rest/in transit, privileged access management, and event/incident reporting tied to national security commitments
  • For cloud, data centers, and AI stacks, expect growing requirements for data localization/segmentation, secure pipelines, and geofencing to align with export and investment conditions

How A&M’s National Security, Trade, and Technology (NSTT) Team Can Help

End‑to‑end technology security and export enablement

• Design and integrate security‑by‑design architectures for AI/HPC consistent with export license conditions, including NIST SP 800‑53‑aligned controls, Restricted Technology Environments, and third‑party security consultant oversight. Our programs have supported early GPU deliveries and sustained regulator trust.
• Implement layered physical, network, compute, storage, application, and monitoring controls that meet authorization conditions while supporting operational scale and ROI.

Enhanced due diligence and audits with regulator credibility

• Conduct comprehensive trade compliance audits and forensic transaction testing tied to the EAR and FDPR, with interviews, global site work, and document reviews, delivering findings that withstand regulator and counsel scrutiny.
• Build and operationalize adaptive trade compliance programs, integrating controls appropriate and adjustable to relevant regulatory and policy risks.

Investment screening, mitigation, and oversight

• Provide CFIUS lifecycle services—prefiling risk analyses, mitigation design, and mitigation oversight—plus outbound and non‑US screening support to reduce execution risk and post‑close friction.
• Develop and operationalize FOCI mitigation, facility clearances, and OPSEC/CUI controls for US government‑facing programs and sensitive infrastructure.

Data security and regulated‑data assurance

• Conduct DSP risk and compliance assessments, [10] harmonize regulated‑data frameworks (e.g., bulk sensitive data, CUI, ITAR/EAR, FAR/CMMC), define and secure regulated data environments, implement control baselines, and build authorization/assurance cases aligned to relevant requirements.
• Design insider‑threat and sensitive data security, privileged access governance, and incident reporting structures consistent with national security commitments and oversight obligations. 

[1]. The White House, National Security Strategy of the United States of America, November 2025.

[2]. Randall Cook et al., “America First Investment Policy - Disruption and Opportunity,” Alvarez & Marsal, March 19, 2025.

[3]. The White House, America’s Action Plan, July 2025.

[4]. Randall Cook et al., “What the US AI Action Plan Means for Export Controls and US National Security,” Alvarez & Marsal, September 23, 2025.

[5]. Randall Cook et al., “Enhanced due diligence: The new compliance standard for mitigating trade disruption risk,” Export Compliance Manager, May 2025.

[6]. Cook et al., “What the US AI Action Plan Means for Export Controls and US National Security.”

[7]. Cook et al., “America First Investment Policy - Disruption and Opportunity.”

[8]. Rendall Cook et al., “Your Sensitive Data Is Now a National Security Matter: The DOJ’s New Data Security Program,” Corporate Compliance Insights, April 29, 2025.

[9]. Randall Cook et al., “DOJ Clarifying Guidance on Bulk Sensitive Data DSP: Operational Considerations,” Alvarez & Marsal, April 16, 2025.

[10]. Ibid.