Compliance professionals involved in corporate training, watch this development: President Trump has ordered federal agencies to review their training programs and cancel any diversity training that contains certain keywords or concepts the White House deems “un-American propaganda.” 

The Office of Management & Budget, which acts as the managerial conduit between the White House and the rest of the federal government, circulated a memo on Friday directing all agencies to identify any spending related to training on “critical race theory” or “white privilege,” among other issues. 

The agencies should then explore all possible ways to cancel those contracts or otherwise “divert federal dollars away from these un-American propaganda training sessions.”

Perhaps we let the OMB memo speak for itself:

All agencies are directed to begin to identify all contracts or other agency spending related to any training on “critical race theory,” “white privilege,” or any other training or propaganda effort that teaches or suggests either (1) that the United States is an inherently racist or evil country or (2) that any race or ethnicity is inherently racist or evil. In addition, all agencies should begin to identify all available avenues within the law to cancel any such contracts and/or to divert federal dollars away from these un-American propaganda training sessions.

The memo promises that OMB will provide additional guidance in coming weeks about how to implement the directive. 

What prompted these marching orders? The memo only says “it has come to the president’s attention” that federal agencies have spent millions on training with supposedly anti-American messages, and then continues: 

According to press reports, employees across the executive branch have been required to attend training where they are told that “virtually all white people contribute to racism” or where they are required to say that they “benefit from racism.” According to press reports, in some cases these training have further claimed that there is racism embedded in the belief that America is the land of opportunity or the belief that the most qualified person should receive a job.

So, um, press reports that came to Trump’s attention — that’s what prompted this directive. 

Let’s Be Honest Here

Of course any statement from President Trump should be met with skepticism. Then again, it’s also true that speculating about what passes for thought inside Trump’s head is a perilous exercise.

Still, let me posit a theory. 

Somewhere in the vast federal bureaucracy, some ethics or training officer did buy into some warped, cockamamie version of diversity training that took the message of anti-racism too far. That incident ended up on Fox News or OAN, the two television networks Trump apparently watches 22 hours a day. Trump saw that segment, and construed it to mean that secret agents of antifa have infiltrated the government’s training program. Hence this directive. 

That’s my guess, at least. 

Nor should we ignore the timing of things. The OMB memo arrived 24 hours after the explosive story that Trump has called veterans, prisoners of war, and soldiers killed in combat “losers” and “suckers.” The president needed a change of subject, especially with his political base of white supremacists. This memo provides one way to do that.

In other words, we have a memo that seems one part impulsive outburst, and one part political theater. Perhaps, like many other Trump pronouncements, it won’t amount to much. But compliance officers can’t rest assured of that, so let’s consider some implications. 

Who Feels the Training Squeeze

Several groups might feel consequences of Trump’s memo. 

First, ethics and training officers within federal agencies will need to take this directive seriously because Trump is their boss. So they’ll need to examine any diversity training that might use the forbidden words — “white privilege” and “critical race theory” at least, and perhaps more to come in future guidance. They’ll also need to decode that line about any training that suggests the “United States is an inherently racist or evil country,” whatever that might mean. 

trainingSecond, training vendors who bid on government contracts might see their own diversity training materials subject to new scrutiny, all through Trump’s white supremacy lens. If you can’t even mention the concept of white privilege — which is totally a thing, as anyone in an interracial marriage can tell you — that’s going to challenge how you create training materials. You might also want to review the contracts you currently have with government agencies, to see what early exit clauses Uncle Sam might use against you. You might want to reconsider contract terms for future deals, to get more cash up front in case of arbitrary presidential decree. 

My third point is more speculative. If Trump secures a second term, will he try to force more ill-defined standards like this on the private sector? 

For example, I could easily imagine a scenario where Trump extends this standard for diversity training to government contractors. Or he encourages private sector employees to report “suspicious” diversity training to OSHA or the Justice Department for investigation. Or he tells people to complain to their own HR or compliance departments, because fanning the flames of white grievance is a favorite Trump pastime. Or he forces through similar moves on training for gender equity, religious tolerance, or other issues.

How legally enforceable would any of those moves be? Well, in a second Trump term — who’s going to care? Not the president himself. Not his minions in the executive branch, who can tie corporations into knots with investigative or regulatory costs. Not his minions in the private sector, who will just make corporate compliance and HR missions that much more difficult. 

So I want to dismiss this OMB memo as yet another example of claptrap from an endangered president trying anything he can to whip up his political base. But there’s just enough potential headache here that compliance professionals should watch this issue, in case its practical effects hit your program.

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