Insight
Client Alerts
January 13, 2026 • 1-minute read
Vinson & Elkins’ 2025 Energy & Chemicals Antitrust Report details how antitrust enforcement under the second Trump administration has shifted toward a more traditional, pragmatic, and business-friendly approach while remaining firmly committed to vigorous enforcement. New leadership at the DOJ and FTC reaffirmed the 2023 Merger Guidelines for stability, reinstated early termination of HSR reviews, and showed greater openness to negotiated settlements—particularly structural remedies such as divestitures—rather than reflexively blocking mergers.
Enforcement activity in the energy and chemical sectors declined compared to prior years, with fewer merger challenges and the rollback or modification of several Biden-era consent orders, especially in oil and gas. At the same time, agencies continued to prioritize consumer welfare and labor market competition, pursuing cases involving retail fuel, construction materials, wage-fixing, non-competes, and unlawful pre-closing coordination, while imposing record civil penalties for HSR violations.
State attorneys general expanded their role through new “Mini-HSR” laws and increased scrutiny of federal settlements, creating a more complex enforcement landscape. Overall, the report depicts an environment that is more receptive to M&A but still active, disciplined, and enforcement-oriented, with heightened compliance burdens driven by expanded HSR filing requirements and ongoing non-merger investigations.
This information is provided by Vinson & Elkins LLP for educational and informational purposes only and is not intended, nor should it be construed, as legal advice.
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