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On March 1, 2025, the Texas Business Court (the “Business Court”) implemented new local rules aimed at enhancing the efficiency and fairness of business dispute resolutions. Key changes include new provisions involving exchanging benches, supplemental jurisdiction waivers, corporate disclosure requirements, streamlined discovery dispute procedures, the concept of a Mediation Wheel, and a new guideline for the use of artificial intelligence. These rules, unanimously approved by all ten judges, mark a significant shift in the Business Court’s operational framework.

On April 8 and 9, 2025, President Donald Trump issued five Presidential Actions (four Executive Orders and one Proclamation, collectively “Presidential Actions”) for the purposes of ensuring adequate and reliable energy generation, meeting growing energy demand, and addressing the national energy emergency declared on January 20, 2025 (EO 14156).

As we previously discussed and in alignment with the U.S. Treasury Department’s previous announcement, on March 21, 2025, the Financial Crimes Enforcement Network (“FinCEN”) issued an interim final rule that dramatically narrows the reporting requirements for beneficial ownership information (“BOI”) under the Corporate Transparency Act (“CTA”).

A series of recent actions undertaken by President Biden, near the end of his term, and President Trump, in the early days of his presidency, have called into question a key issue under the Outer Continental Shelf Lands Act (“OCSLA”) — whether the President can revoke a previous President’s withdrawal of areas of the United States Outer Continental Shelf (“OCS”) from oil and gas leasing.

The opening days of the 119th U.S. Congress have been marked with congressional action under the Congressional Review Act (CRA) to potentially invalidate regulations that were issued by the Internal Revenue Service (IRS) in the final days of the Biden administration.

On February 27, 2025, the Financial Crimes Enforcement Network (“FinCEN”) announced a suspension of enforcement actions related to the Corporate Transparency Act (“CTA”).

On February 26, 2025, the Supreme Court and all three counsel appearing before it in Ames v. Ohio Department of Youth Services, appeared to walk away in “radical agreement” — as noted by Justice Neil Gorsuch — that a majority-group plaintiff is not required to proffer more evidence of discrimination than a non-majority-group plaintiff in order to state a prima facie claim under Title VII of the Civil Rights Act of 1964.

On February 19, 2025, the Council on Environmental Quality (“CEQ”) released a pre-publication version of an interim final rule (the “Interim Rule”) to rescind all of CEQ’s previous and current regulations implementing the National Environmental Policy Act (“NEPA”) alongside a memorandum (the “Memo”) to federal agencies providing guidance on how agencies should revise their individual NEPA regulations and how they should manage NEPA reviews in the meantime.

In his first two days in office, newly inaugurated President Donald J. Trump signed a flurry of Executive Orders, including several aimed at supporting the traditional energy industry.

On February 12, 2025, the Division of Corporate Finance (the “Staff”) of the U.S. Securities and Exchange Commission (the “SEC”) issued new guidance on Rule 14a-8 shareholder proposals, which comes one day after the Staff posted new Compliance and Disclosure Interpretations (“C&DI”) in connection with shareholder communications and Schedule 13G eligibility.

For more than twenty years, the North American Free Trade Agreement (“NAFTA”), and later, the United States‑Mexico-Canada Agreement (“USMCA”), have facilitated cross-border trade and investment among the United States, Mexico, and Canada through the elimination of virtually all financial barriers to trade.

On January 13, 2025, Texas Attorney General Ken Paxton (“Texas AG”) filed the first-ever enforcement action under the Texas Data Privacy and Security Act (“TDPSA”) against insurance company Allstate and its subsidiary, Arity (collectively, “Defendants”).