Introducing the Think Tank Preparing for a Potential Second Trump Administration (Not Project 2025)
The America First Policy Institute has been discreetly working on plans for a potential second Trump administration.
Key figures from Trump's previous administration have been meticulously reviewing regulations implemented during Biden's presidency, engaging with numerous former officials, and drafting executive actions to facilitate a smooth transition back into power if Trump is successful. The aim is to establish a streamlined administration capable of swiftly dismantling President Joe Biden's legacy, learning from the disorder that characterized Trump's 2016 transition.
Unlike the high-profile Project 2025 spearheaded by the Heritage Foundation, which has been criticized by Trump and has become a target for opposition, this planning is primarily being led by the America First Policy Institute (AFPI).
This preparatory work has largely occurred independently of the formal Trump campaign, whose transition efforts are reportedly lagging behind the timeline of his initial presidential run. However, Trump and his senior advisors are aware of AFPI's initiatives, which many in the Republican Party see as a vital addition to official transition planning—as long as it remains discreet and does not provoke Trump.
Founded in 2021 with Trump's endorsement, AFPI consists of loyalists and associates from his administration. CEO Brooke Rollins has maintained a close relationship with Trump and has discussed the organization’s transition strategies with him. Most recently, Trump appointed Linda McMahon, the group’s board chair, to co-lead the official transition team.
“For three and a half years, AFPI has focused on personnel and policy. It was formed by and is teeming with senior staffers from the first Trump Administration whose goal is to be ready on day one,” said Kellyanne Conway, former Trump advisor and current chair of AFPI’s Center for the American Child. She added, “Linda McMahon, Brooke Rollins and the team have planned with precision and executed with put-your-head-down type humility.”
Lobbyists have noticed AFPI's activities and are encouraging their clients to engage with the group or contribute policy ideas. The think tank prioritizes deregulation and reducing the federal government's scope. "It has been ‘drinking from the fire hose,'" noted one lobbyist who is consulting AFPI, adding that the think tank is "in the driver seat on transition." (Most respondents in this article were granted anonymity to discuss sensitive issues within Trump's sphere.)
As a 501(c)(3) nonprofit, AFPI is prohibited from endorsing political candidates. The organization stresses its independence from any specific campaign, making efforts to avoid the kind of public backlash that has beset the Heritage Foundation's Project 2025.
AFPI representatives "have been quietly focused on helping current and future leaders at the local, state and national level enact policies to reverse the damage caused by the radical left and put the interests of the American people first,” the think tank said in a statement. “AFPI does not speak on behalf of any officeholder or campaign.”
Nevertheless, AFPI boasts extensive connections to Trump and his allies, positioning it as an essential player in 2025 preparations, especially given the official campaign's slow pace in developing a solid transition plan.
“AFPI is not becoming the transition,” said a source familiar with the Trump campaign's transition efforts, granted anonymity to discuss internal strategies. “But by virtue of how they are situated and that we are in a very late timeline for this work, AFPI and the transition may be a distinction without a difference.”
The think tank's association with election denialism, particularly regarding its involvement in a Georgia lawsuit concerning local officials' authority to contest election result certifications, has attracted criticism from the left.
AFPI is well-funded, operating as a 501(c)(3) "dark money" organization that does not reveal its donors. It reported $23.6 million in revenue in 2022, with some former Trump officials receiving significant compensation. Key figures in the group, often referred to as Trump’s “White House in waiting,” include Rollins and Larry Kudlow, the former National Economic Council director.
Trump has held fundraisers for AFPI at his Mar-a-Lago estate, his PAC Save America has financially supported the group, and his first major post-presidency speech was delivered at an AFPI event.
“They got permission from Trump,” said Bryan Lanza, a lobbyist who was part of Trump's initial transition team. “Linda’s a former Cabinet official, she’s now in the transition. I think that sort of shows that there’s some connective tissue.”
While AFPI has yet to make public its final transition plans for a future Trump presidency, its publicly available agenda emphasizes deregulating the federal government, expanding rights for religious organizations, and a vigorous crackdown on crime, among other priorities. The agenda includes boosting oil and gas production, completing the border wall, and limiting federal spending. It has also advocated for designating Antifa as a domestic terrorist group and making Trump's tax cuts permanent.
Staffers at AFPI have conducted extensive research, targeting areas such as "management, personnel, policy, financial, and administrative" strategies for effective federal governance. According to one source familiar with their operations, AFPI has completed over 1,000 interviews with former officials and reviewed every Biden executive order, with plans to draft more than 100 proposed executive actions. The group has also identified key positions to prioritize for staffing in a future administration.
As AFPI designs its framework for a potential Trump presidency, lobbyists have looked to shape its agenda, with some urging the organization to focus on reversing Biden’s labor policies, a priority for their clients.
One lobbyist stated that there is a common misperception that direct access to Trump is the most effective way to influence White House policy. “On economic issues, regulatory matters, policy issues, it’s not that straightforward," the lobbyist noted. "In fact, most of the time, you have to work bottom up."
AFPI has solicited recommendations for federal department priorities and sought advice on initiatives for the first day, first 100 days, and first 200 days of a new administration.
“Their goal is ... to get a structure in place that will allow for the correct formula of personnel and pursuing the right policy early on,” said one Republican lobbyist involved in the Trump administration. “They have stuff ready to go off the shelf that they can present as options.”
These initiatives are aimed at ensuring a smoother transition for a potential future Trump administration, particularly after the chaotic experience of 2016, when the initial transition effort led by Chris Christie was abruptly terminated.
"We have announced a transition leadership team and expanded the team this week,” stated Trump campaign spokesman Brian Hughes. He mentioned that both the transition team and campaign are gearing up “for the hard work of undoing the failure and chaos” of the Biden-Harris administration, emphasizing that “Transition efforts, as with the campaign, implement President Trump's agenda, and after a victory in November it will be President Trump who leads the work to build the team for an historic next term leading our nation."
According to an insider, the current official transition also remains in its early stages, with vetting for cabinet positions and initial discussions of potential candidates still in the works, despite Trump having already floated various names for key roles.
In mid-August, Trump announced that McMahon and Howard Lutnick, a close friend and supporter, would lead the transition team. His sons, Eric Trump and Donald Trump Jr., along with running mate Sen. JD Vance, were named honorary co-chairs, with Robert F. Kennedy Jr. and Tulsi Gabbard later added, although their precise influence on personnel or policy remains uncertain.
Camille Lefevre contributed to this report for TROIB News