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On May 19, 2025, Deputy Attorney General Todd Blanche issued a memorandum announcing the creation of the Department of Justice’s (DOJ) Civil Rights Fraud Initiative (the Initiative), which directs DOJ attorneys to utilize the False Claims Act (FCA), 31 U.S.C. § 3729 et seq., to combat knowing violations of civil rights law and the false certification of compliance with such laws by recipients of federal funds such as educational institutions and federal contractors.

On May 22, 2025, the House passed budget reconciliation legislation referred to as “The One, Big, Beautiful Bill” (the “Bill”).

One hundred days ago, sweeping revisions to the Hart-Scott-Rodino Act Premerger Notification Form took effect.

On April 2, 2025, President Donald Trump announced a new tariff regime under the International Emergency Economic Powers Act of 1977 (“IEEPA”), citing national security concerns. This regime includes a 10 percent baseline tariff for all countries and higher “reciprocal tariffs” for approximately 90 countries, effective April 5, and April 9, 2025, with additional potential tariffs threatened in the future. The new tariffs would significantly impact corporations, particularly those with supply-chain exposure in China and other Southeastern Asian countries.

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.

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 Federal Trade Commission (“FTC”) announced the formation of a Joint Labor Task Force aimed at addressing deceptive, unfair, and anticompetitive practices impacting labor markets.

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.

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.