Treasury launches Strategic Vendor Program pilot and seeks input from market participants

The United States Department of the Treasury, as chair of the Committee on Foreign Investment in the United States (CFIUS), has announced a new pilot Strategic Vendor Program and is seeking input from stakeholders, including law firms and their clients, on companies’ supply chain challenges.

The program is consistent with the US open investment policy and reinforces other messaging from Treasury leadership aimed at improving CFIUS processes and adopting a more customer-focused approach. The program aims to facilitate access to US-based vendors for companies operating in the US following CFIUS clearance. In an accompanying letter received by DLA Piper, Treasury emphasized that participation in the program is voluntary and will have no bearing on any current or future CFIUS submissions.

Overview of the Strategic Vendor Program

According to Treasury, the Strategic Vendor Program is intended to raise awareness of the domestic vendor base available to companies whose transactions have cleared the CFIUS review process. The program aims to support a resilient US supply chain by connecting companies with domestic suppliers and service providers that may be better positioned to meet their operational and security requirements.

To support this effort, Treasury plans to coordinate with other US government agencies, including the Department of Defense’s Office of Strategic Capital, the Department of Commerce’s SelectUSA program, and the US Small Business Administration. These agencies may assist in identifying and supporting domestic vendors through existing networks and, where appropriate, capital support, loans, or other development tools. The initiative is consistent with the Trump Administration’s dual-protect-and-promote approach to investment.

As part of the pilot phase, Treasury is requesting feedback on:

• Industries where companies have experienced difficulty identifying or engaging domestic vendors, suppliers, or manufacturers
  
  
• Areas where US-based suppliers face capacity constraints or capital limitations that may affect their ability to support company growth

Treasury has indicated a preference, during the pilot phase, to focus on companies that do not currently have matters pending before CFIUS.

Potential implications for companies

The Strategic Vendor Program represents a notable development in how Treasury engages with companies that participate in the CFIUS process. While CFIUS has historically focused on identifying and mitigating national security risks associated with foreign investment, this initiative suggests a broader emphasis on strengthening domestic supply chains and supporting the long-term success of foreign-invested businesses operating in the US.

This program presents an opportunity for companies to:

• Identify US-based vendors and suppliers in sectors where domestic capacity is limited
  
  
• Highlight supply chain constraints and operational challenges directly to Treasury outside the context of a pending transaction
  
  
• Engage with interagency partners that may be positioned to support vendor development and supply chain resilience
  
  
• Position themselves as trusted vendors available to support US industry’s efforts to increase supply chain resiliency

At the same time, the program’s scope and implementation are still under development. Treasury has not provided detailed guidance on how vendors will be identified or curated, whether participation will lead to any formal designation or recognition, how information shared through the program may be used or protected beyond existing confidentiality frameworks, or how this program may overlap with defense-sector promotion initiatives.

Position within evolving US investment security policy

The Strategic Vendor Program may be viewed in the context of maintaining the US open investment policy and broader US government efforts to align foreign investment policy with economic security priorities. Recent initiatives – including the development of the CFIUS Known Investor Program and other policy measures stemming from the Administration’s “America First” investment framework – reflect an increasing focus on both streamlining investment from trusted partners and strengthening domestic capabilities in critical sectors.

Taken together, these developments suggest a continued evolution of CFIUS’s mission areas, now including investment promotion efforts alongside the transaction-focused review mechanism. This broader framework linking national security reviews and industrial policy may improve efficiency for investors and companies while reinforcing supply chain resilience.

What companies should consider

In light of Treasury’s announcement, companies may wish to consider evaluating whether to:

• Leverage the program to address critical supply chain constraints, including identifying and securing qualified US-based vendor alternatives to reduce reliance on higher-risk or foreign suppliers
  
  
• Engage strategically with Treasury and interagency partners to align with emerging US government priorities, including potential access to funding, capital deployment initiatives, or other policy-driven support mechanisms
  
  
• Shape the government’s understanding of sector-specific challenges by providing specific, practical input that may inform more commercially viable and operationally effective policy outcomes

How DLA Piper can help

DLA Piper is engaged directly with the US Department of the Treasury to support this effort and is positioned to assist companies and investors in participating in the Strategic Vendor Program and related initiatives.

DLA Piper’s National Security and Global Trade practice combines deep CFIUS and regulatory experience with a strong government affairs capability, enabling us to advise on both compliance and strategic engagement with key CFIUS member agencies.

With a global team of more than 100 lawyers, including former senior government officials, we help businesses navigate complex supply chain and investment issues, shape government-facing positions, and align with evolving US national security priorities.

Learn more

Please contact any of the authors or your usual DLA Piper contact for further information.