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A federal district court in Louisiana has rejected as unlawful President Joe Biden’s withdrawal in early January 2025 of historically large portions of the Outer Continental Shelf (“OCS”) from eligibility for leasing of oil and natural gas.

An oil major (“the Company”) filed suit in federal court on October 24, 2025, challenging California’s Climate Laws — the Climate Corporate Data Accountability Act (“SB 253”) and the Climate-Related Financial Risk Act (“SB 261”) — on the basis that the laws violate the Company’s First Amendment rights.

From October 14–17, 2025, the Marine Environment Protection Committee (“MEPC”) of the International Maritime Organization (“IMO”) convened an extraordinary session in London to consider formal adoption of draft amendments to Annex VI of the International Convention for the Prevention of Pollution from Ships, including the IMO Net-Zero Framework.

On October 15, 2025, Louisiana Governor Jeff Landry issued an Executive Order (“Order”) halting the review of all new Class VI Underground Injection Control (“UIC”) well permits in the state and directed the state’s regulator, the Louisiana Department of Conservation and Energy (“LDCE”) to undertake a more careful review of pending Class VI permit applications.

Participants will hear our panelists discuss the current federal government enforcement landscape in key areas including antitrust, environmental, energy and securities enforcement.

On September 18, 2025, the United States Environmental Protection Agency (“EPA”) published its latest proposed policy in an active year for the Clean Air Act (“CAA”) Renewable Fuel Standard (“RFS”) program.

What can project developers actually build before securing an air permit?

On August 18, 2025, a divided panel of the U.S. Court of Appeals for the Fourth Circuit reversed a district court order dismissing an ethylene oxide (“EtO”) exposure case for lack of Article III standing.

Vinson & Elkins is pleased to offer this round-up of recent developments in federal enforcement, with a particular emphasis on changes during the first few months of the second Trump administration.

On August 22, 2025, the Environmental Protection Agency (“EPA”) announced decisions on 175 small refinery exemption (“SRE”) petitions stretching back over the last four years.

On July 3, 2025, the Federal Energy Regulatory Commission (“FERC” or the “Commission”), the U.S. Army Corps of Engineers (“Army Corps”), and the Departments of Energy (“DOE”), Interior (“DOI”), Transportation (“DOT”), Agriculture (“USDA”), and Defense (“DOD”) released sweeping updates to their regulations and procedures implementing the National Environmental Policy Act (“NEPA”).

The federal government is continuing to implement President Donald Trump’s Unleashing American Energy mandate to promote domestic energy and infrastructure projects.