Rollback, Regulatory Freezes, and Investigations Review

  • Since the 2014 adoption of asset-level disclosure requirements, there has not been a single public offering of residential mortgage-backed securities. Market participants have cited these requirements as a key barrier to the return of the public securitization market.
  • New and expanding types of asset-backed securities have prompted

The plan seeks to limit AI regulation at the federal and state level, encourages rapid development of AI infrastructure, and warns against ideological bias in models.

By Michael H. Rubin, Sy Damle, Andrew Gass, Ghaith Mahmood, and Fiona M. Maclean

On July 23, 2025, the Trump administration released a 28‑page AI strategy document titled “Winning the Race: America’s AI Action Plan” (the Action Plan or Plan). The Action Plan was drafted pursuant to Executive Order 14179

On June 9, 2025, Deputy Attorney General Todd Blanche issued a memorandum (the Guidelines) on “Guidelines for Investigations and Enforcement of the Foreign Corrupt Practices Act (FCPA)” by the US Department of Justice (DOJ).

The Guidelines follow President Trump’s February 10, 2025, executive order (the Executive Order), which directed DOJ to “(i) cease initiation of any new FCPA investigations or enforcement actions, unless the Attorney General determines that an individual exception should be made; (ii) review in detail all existing FCPA investigations or enforcement

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

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. LongPia NaibConnor 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