On March 6, 2026, President Trump signed an Executive Order (“EO”) titled "Combating Cybercrime, Fraud, and Predatory Schemes Against American Citizens." The EO announces a plan by the Administration to counter transnational criminal organizations (TCOs) that leverage cyber-enabled tools to target American families, businesses, and critical infrastructure.
This EO outlines a framework for a more centralized federal response to cyber-enabled threats. By establishing a dedicated operational cell within the National Coordination Center (NCC) to strengthen coordination across government and industry and utilizing diplomatic channels to address foreign jurisdictions that host cybercrime, the Administration seeks to disrupt the financial networks and "shadow economy" supported by identity theft and exploitative labor practices.
In particular, recognizing that TCOs operate across borders, the EO directs the Secretary of State, in coordination with the NCC, to engage with foreign governments to enforce actions against such groups, enhance cooperation with US law enforcement, and ensure accountability when nations allow such activities to continue. Notably, potential measures include limiting foreign assistance, imposing targeted sanctions or visa restrictions, applying trade penalties, and, when applicable, expelling from the US foreign officials or diplomats found to be complicit.
The Administration Releases President Trump’s Cyber Strategy for America
Alongside the EO, the Trump Administration released President Trump's Cyber Strategy for America, which emphasizes the coordination of offensive and defensive capabilities to maintain technological parity in cyberspace. This strategic vision is anchored by six policy pillars that will guide federal action going forward:
- Shape Adversary Behavior: Deploying the full suite of US government defensive and offensive operations, as well as providing incentives for the private sector, to help disrupt cybercrime, raise costs for aggressors and uproot criminal infrastructure.
- Promote Common Sense Regulation: Streamlining cyber and data regulations to reduce compliance burdens and ensure the private sector has the agility necessary to keep pace with evolving global threats.
- Modernize and Secure Federal Government Networks: Requiring the implementation of zero-trust architecture, post-quantum cryptography, and AI-powered solutions to deter intrusions at scale. The strategy further calls for modernized procurement processes to remove barriers to entry, ensuring the government can utilize the most advanced commercial technology.
- Secure Critical Infrastructure: Hardening supply chains of the energy grid, financial systems, hospitals, and water utilities while moving away from adversary-sourced technology.
- Sustain Superiority in Critical and Emerging Technologies: Securing the AI technology stack and data centers, promoting the adoption of post-quantum cryptography, and supporting the security of blockchain technologies.
- Build Talent and Capacity: Eliminating roadblocks to develop a highly skilled cyber workforce through alignment between industry, academia, and government. The strategy envisions a pragmatic talent pipeline that spans vocational schools, companies, and venture capital opportunities.
This EO and Cyber Strategy appear to build upon previous actions by the Trump Administration, including the 2025 TAKE IT DOWN Act and earlier orders focused on disrupting cybercrime and protecting critical infrastructure networks. This latest announcement aligns with several trends, including increased scrutiny of cyber threats, focus on offensive actions in addition to defensive measures, and use of sanctions and diplomatic pressure to further these goals. The Cyber Strategy notes that follow-on policy vehicles will be forthcoming, which the Freshfields team will continue to monitor.
