The Missing Convener: NSC’s Diminished Role and the Future of U.S. Investment Security

(Eric S. Johnson – Just Security) The United States has built an investment security architecture over the preceding decades of unprecedented breadth. Whether it functions as a coherent interagency system — one that gives policymakers, aligned governments, and the private sector the certainty needed to engage meaningfully with the screening regimes — depends on whether the institution designed to hold the interagency together, the National Security Council, is permitted to do its job. It is not. The National Security Council has been under sustained institutional stress throughout the current Administration. The sidelining of approximately 160 career officials detailed from CIA, FBI, State, DOJ, and other agencies in January, followed by the abrupt mass dismissal of numerous career officials in the spring and the removal of the National Security Adviser — with the post now held concurrently by the Secretary of State — has dispersed the institutional cadre on which the NSC’s coordination function depends. The Financial Times observed in August 2025 that the traditional foreign policy process led by the NSC has “largely broken down”. The scale of what is at stake is considerable. The Committee on Foreign Investment in the United States (CFIUS) is building the Known Investor Program (KIP) to streamline reviews for low-risk investors. Treasury must issue COINS Act regulations by March 2027, expanding the Outbound Investment Security Program to cover new technologies and geographies. The Department of Justice’s Data Security Program (DSP), which functions as export controls for bulk sensitive personal data, entered full enforcement last July. Commerce’s Office of Information and Communications Technology and Services (OICTS) is extending its ICTS supply chain authorities into connected vehicles, drones, and cloud computing. Each initiative requires not just a legal foundation and significant agency focus, but sustained interagency policy coordination — the kind that only a functioning NSC is positioned to provide. The consequences of the NSC’s diminished role will not be felt primarily through the review of any single transaction. They will be felt in the quality and clarity of the rules themselves, and ultimately in the loss of the predictability that policymakers, aligned governments, and repeat participants require to engage the system with confidence. That loss of predictability itself poses national security risks: fragmented and uncoordinated frameworks invite circumvention, produce uneven enforcement, and corrode the credibility of the overall regime in the eyes of governments whose cooperation the United States is simultaneously seeking. – NSC’s Diminished Role and the Future of U.S. Investment Security