Time to Choose Act of 2025
Key claim: The Time to Choose Act of 2025 would prohibit federal agencies from awarding consulting-services contracts to any entity that also provides consulting to covered foreign entities such as the Chinese government/CCP/PLA, Russia-sanctioned parties, state sponsors of terrorism, and certain Commerce Department restricted lists, unless a national-security waiver is granted.
Abstract
(HR2989 · 119th Congress) Time to Choose Act of 2025 This bill prohibits the federal government from awarding consulting services contracts to any entity that provides consulting services to covered foreign entities. Foreign entities covered by the bill include the government of China, the Chinese Communist Party, the People’s Liberation Army, or any Chinese security service or intelligence agency; the government of Russia or any entity sanctioned under Executive Order 13662 ; the government of any country determined by the Department of State to have repeatedly provided support for international terrorism; and any entity on certain lists maintained by the Department of Commerce, such as the Denied Persons List or the Military End User List. An agency may waive the prohibition on a case-by-case basis if it is in the national security interests of the United States and no other entity without a conflict of interest can perform the work. Latest action (2025-04-24): Referred to the House Committee on Oversight and Government Reform.
Why this matters
The Act would extend adversary-focused trade and sanctions logic into federal procurement of consulting services, forcing multinational advisory firms to choose between U.S. government business and clients on Commerce/OFAC restricted lists. If enacted, it creates a compliance chokepoint that effectively exports U.S. export-control designations into the services market, with knock-on effects for firms that currently sit on both sides.