If finalized, the rule would eliminate both Obama- and Biden-era limits on GHG emissions from fossil fuel-fired power plants.
By Karl A. Karg, Stacey L. VanBelleghem, Nikki Buffa, Devin M. O’Connor, and G. Jack Mathews
On June 11, 2025, the US Environmental Protection Agency (EPA) released a proposed rule under the Clean Air Act (CAA) titled “Repeal of Greenhouse Gas Emissions Standards for Fossil Fuel-Fired Electric Generating Units” (the Proposed Repeal).
Under the current Obama- and
The executive order shifts policy on enforcement of criminal regulatory offenses, steering away from criminal enforcement of strict liability offenses in regulatory matters.
By Jennifer L. Bragg, Nicholas McQuaid, and Terra Reynolds
On May 9, 2025, President Trump issued an executive order titled “Fighting Overcriminalization in Federal Regulations” (the Order), aimed at reducing criminal enforcement of federal regulatory offenses in general and strict liability offenses, in particular. The Order also includes several requirements for agencies to increase transparency
The Department of Justice has established a new Civil Rights Fraud Initiative, which will leverage the False Claims Act to investigate and pursue claims against recipients of federal funds who “knowingly violate civil rights laws.”
By Danielle Conley, Terra Reynolds, Anne W. Robinson, Jude Volek, and Savannah Burgoyne
In a memorandum dated May 19, 2025, Deputy Attorney General Todd Blanche announced the establishment of a new Civil Rights Fraud Initiative (the Initiative) at the Department of
General License 25 effectively suspends OFAC sanctions targeting Syria. Stringent US export control restrictions on exports and reexports to Syria remain.
By Les P. Carnegie, Damara Chambers, Charles Claypoole, Andrew P. Galdes, Robert Price, Eric S. Volkman, Ruchi G. Gill, Amaryllis Bernitsa, Monica Calce, Matthew Crawford, Eric Green, Matthew R. Gregory, Joelle Hageboutros, Margaret Hynds, Thomas F. Lane, Juan Miramontes, Katherine Ryan, C.J. Rydberg
New federal legislation aims to combat the publication of non-consensual deepfakes and mandates notice-and-removal procedures for covered platforms.
By Sy Damle, Andy Gass, Ghaith Mahmood, and Michael H. Rubin
On May 19, 2025, President Trump signed into law the “Tools to Address Known Exploitation by Immobilizing Technological Deepfakes on Websites and Networks Act” (the Take It Down Act or the Act). The Act, which received widespread bipartisan support, prohibits any person from knowingly publishing “intimate visual depictions”
The OCC is restoring its former practices and policies under the Bank Merger Act to reinstate expedited merger reviews and streamlined business combination applications.
By Arthur S. Long, Pia Naib, Connor Jobes, and Deric Behar
On May 8, 2025, the Office of the Comptroller of the Currency (OCC) issued an interim final rule (Interim Final Rule) to rescind a 2024 final rule (2024 Final Rule) that amended the OCC’s bank merger application review procedures. The OCC simultaneously
Recent developments include leadership changes, workforce reductions, and policy shifts at HHS and FDA, reshaping agency operations under President Trump’s administration.
By Nathan A. Beaton, Jennifer L. Bragg, William A. McConagha, and Trevor Thompson
Since his inauguration, President Trump has focused on reshaping federal agencies through a series of executive orders intended to reduce the size of the federal workforce and dramatically alter the landscape in which agencies operate. In turn, Department of Health and Human Services
The federal banking agencies continue to open the channels for regulated entities to engage in digital asset activities.
By Arthur S. Long, Parag Patel, Pia Naib, and Deric Behar
On May 7, 2025, the Office of the Comptroller of the Currency (OCC) published Interpretive Letter 1184 (a response to an inquiry from a regulated entity) affirming that national banks and federal savings associations (collectively, banks) may provide and outsource cryptocurrency custody and execution services on behalf of
The Trump administration continued its focus on immigration and indicated progress in trade talks as this week marked the end of its first 100 days.
This week, President Trump issued several executive orders related to immigration, tariffs, and media bias. Meanwhile, the administration signaled that it has made progress in trade talks with various countries. Below is a high-level overview of the administration’s actions, broken down by topic, along with updates on related court challenges, personnel changes, and other breaking
Potential policy changes could offer opportunities for CFIUS filers in low-risk transactions while introducing added challenges for transaction parties linked to sensitive countries.
By James Barker, Les Carnegie, Damara Chambers, Paul Rosen, Zachary Eddington, Ruchi Gill, and Catherine Hein
On April 24, 2025, Deputy Secretary of the Treasury Michael Faulkender spoke on the Committee on Foreign Investment in the United States (CFIUS) and the Outbound Investment Security Program at the American Conference Institute’s annual CFIUS