Further Extending the TikTok Enforcement Delay

9/16/2025

Executive Orders

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Action Summary

Enforcement Delay Extension: The enforcement delay for provisions of the Protecting Americans from Foreign Adversary Controlled Applications Act concerning TikTok is extended until December 16, 2025, covering all conduct from January 19, 2025, through the issuance of this order.
Department of Justice Restrictions: During the extended period, the DOJ is directed not to enforce the Act or impose any penalties for noncompliance, including for distributing, maintaining, or updating any foreign adversary controlled application.
Attorney General Guidance: The Attorney General is tasked with issuing written guidance and a letter to providers, affirming that no statutory violations or liabilities will be pursued for acts occurring during the specified period or from the Act’s effective date until this order.
Executive Authority Emphasis: The order reinforces that only the Attorney General has investigation and enforcement authority under the Act, prohibiting states or private parties from attempting enforcement and thereby safeguarding executive powers.
General Provisions: The order confirms that it does not impair statutory authority of executive departments or the functions of the Office of Management and Budget, and it does not create enforceable rights or benefits for third parties.
Administrative Details: Implementation is subject to applicable law and appropriations, and publication costs will be borne by the Department of Justice.

Risks & Considerations

The extension of the enforcement delay on the TikTok ban indicates ongoing uncertainty regarding the regulation of foreign adversary-controlled applications. This could affect Vanderbilt University’s digital communication strategies, particularly if TikTok is a platform used for outreach or engagement.
There is a potential risk of reputational impact if the university is perceived as non-compliant with national security measures, even if enforcement is delayed. This could affect partnerships and collaborations with government agencies.
The executive order highlights the exclusive authority of the Attorney General to enforce the Act, which may limit the university’s ability to seek state-level guidance or intervention in related matters.
Vanderbilt University may need to monitor developments closely to ensure compliance with any future enforcement actions once the delay period ends, particularly in terms of data privacy and security protocols.

Impacted Programs

Vanderbilt’s Information Technology Department may need to assess the use of TikTok and similar applications within the university’s network to ensure compliance with future regulations.
The Office of Public Affairs might need to develop communication strategies to address any concerns from stakeholders regarding the university’s use of foreign-controlled applications.
Research programs involving data privacy and cybersecurity could see increased relevance and funding opportunities as the national focus on these issues intensifies.

Financial Impact

The delay in enforcement may provide temporary relief from potential financial penalties associated with non-compliance, but the university should prepare for possible future costs related to compliance measures.
There could be opportunities for securing grants or funding for research in cybersecurity and data privacy, aligning with national security priorities.
Vanderbilt may need to allocate resources to ensure that its digital platforms and applications comply with any new regulations once the enforcement delay is lifted.

Relevance Score: 3 (The order presents moderate risks involving compliance and potential reputational impact.)

Key Actions

Vanderbilt’s Legal Affairs Office should monitor the developments regarding the enforcement of the Protecting Americans from Foreign Adversary Controlled Applications Act. Understanding the implications of the extended enforcement delay and any potential future actions by the Department of Justice will be crucial for ensuring compliance and mitigating any legal risks associated with the use of foreign adversary-controlled applications.
Vanderbilt’s Information Technology Department should assess the use of applications that may fall under the Act’s purview. By identifying and evaluating any foreign adversary-controlled applications currently in use, the department can prepare for potential future compliance requirements and ensure that the university’s technology infrastructure remains secure and aligned with national security interests.
Vanderbilt’s Office of Federal Relations should engage with policymakers to understand the broader national security concerns driving this executive order. By staying informed about the legislative and regulatory landscape, the office can advocate for the university’s interests and contribute to shaping policies that impact higher education institutions.

Opportunities

The extended enforcement delay provides an opportunity for Vanderbilt’s Research Centers to explore collaborations with technology companies and government agencies. By leveraging this period to develop innovative solutions that address national security concerns, Vanderbilt can position itself as a leader in research and development in the field of cybersecurity and technology policy.
Vanderbilt’s Political Science Department can conduct research on the implications of the Protecting Americans from Foreign Adversary Controlled Applications Act. This research can provide valuable insights into the balance between national security and technological innovation, contributing to the academic discourse and informing policy decisions.

Relevance Score: 3 (Some adjustments are needed to processes or procedures to ensure compliance and capitalize on research opportunities.)

Average Relevance Score: 3

Timeline for Implementation

Enforcement delay extended until December 16, 2025.

Relevance Score: 2

Impacted Government Organizations

Department of Justice (DOJ): Directed to suspend enforcement of the Act and responsible for implementing the guidance issued by the Attorney General.
Attorney General: Tasked with issuing written guidance, communicating with providers regarding nonviolations, and defending the President’s exclusive authority to enforce the Act.
Office of Management and Budget (OMB): Noted for its budgetary, administrative, or legislative functions, which are to remain unaffected by this order.
State Governments: Although not executing the order, state enforcement actions are expressly discouraged to prevent encroachment on federal authority.

Relevance Score: 2 (Between 3 and 5 agencies are impacted by this executive action.)

Responsible Officials

Department of Justice – Required to refrain from enforcing the Act during the specified period and to bear the publication costs.
Attorney General – Tasked with issuing written guidance, sending letters to service providers to clarify non-liability, and ensuring that enforcement authority remains solely within the executive branch.

Relevance Score: 5 (Directives affect both the Department of Justice and the Attorney General, who are key Cabinet-level officials responsible for national legal and security policies.)