We have reached the six-month anniversary of President Trump’s landmark executive order that extended the regulatory review process run by the White House’s Office of Information and Regulatory Affairs (OIRA) to regulations issued by independent agencies.[1] This order marked an important change for many companies, especially in the financial services and energy sectors,
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DOJ White Collar Enforcement Six Months into the Trump Administration
By Steve Fagell, Nancy Kestenbaum, Aaron Lewis, Stephen Anthony, Lanny Breuer, Eric Carlson, Christopher Denig, Matthew Dunn, Mark Finucane, Sarah Franklin, Jim Garland, Benjamin Haley, Robert Henrici, Geoffrey Hobart, Gerald Hodgkins, Helen Hwang, Robert Kelner, Peter Koski, Amanda Kramer, Kristin Mace, Ashley Nyquist, Matthew O'Connor, Mona Patel, Patrick M. Phelan, Dana Remus, Don Ridings, Krysten Rosen Moller, Simone Ross, Eric Sandberg-Zakian, Jennifer Saperstein, Daniel Shallman, W. Douglas Sprague, Daniel Suleiman, Addison Thompson, Veronica Yepez, Bruce Baird, Frederic Levy, Jean Veta, Alan Vinegrad, Ping An, Matthew Benov, Sarah Bishop, Jason P. Criss, Barbara Hoffman, Ashley Joyner Chavous, Noam Kutler, Teresa Park, Molly Doggett, Dan Grant, Ian Redfearn, Joshua Roselman & Leah Saris
Now that the Trump Administration has cleared the six-month mark, its approach to white collar enforcement is starting to come into focus through multiple policy announcements and an emerging track record. After a flurry of policy announcements from Attorney General Pam Bondi in the early weeks of the new administration, President Trump and the Justice…
U.S. Tariffs and Sanctions Against Brazil and the Brazilian Response
As described in our prior client alert, President Trump threatened in July to impose tariffs of 50% on imports of products from Brazil in response to U.S. concerns regarding Brazil’s criminal prosecution of former President Jair Bolsonaro, recent judicial developments impacting social media regulation in Brazil, Brazil’s allegedly unfair trade practices, and Brazil’s…
Recent Developments in Pet Food and Animal Feed Law & Regulation
The current Congressional session has seen the introduction of bipartisan legislation that, if enacted, would dramatically change the regulatory landscape for pet food and animal feed products. The reintroduced Pet Food Uniform Regulatory Reform Act (PURR Act) would make sweeping changes to the regulatory framework for dog and cat food ingredients and claims in which…
Trump Administration Imposes Secondary Tariffs on India
On August 6, President Trump issued an Executive Order (“EO”) (“Addressing Threats to the United States by the Government of the Russian Federation”) invoking his authority under the International Emergency Economic Powers Act (“IEEPA”) to impose a tariff of 25% on most products imported from India, effective August 27, in response to India’s importation of…
FDA Proposes Extension to Food Traceability Rule Compliance Date
Earlier today, FDA issued a proposed rule that would extend the compliance date of the Food Traceability Rule by 30 months, i.e., until July 20, 2028. The Food Traceability Rule, which is one of the core rules FDA was required to issue under the Food Safety Modernization Act (FSMA), will impose additional traceability recordkeeping requirements on persons…
U.S.-EU Trade Framework: Outcome and Next Steps
On July 27, the United States and the European Union announced a trade framework agreement, following a meeting between President Donald Trump and European Commission President Ursula von der Leyen. The deal avoided imposition of a 30% reciprocal U.S. tariff on EU goods that was set to take effect August 1, and a potential EU…
UN World Court Finds Consequences of Climate Change Underscore Its Existential Threat
On 23 July 2025, the International Court of Justice (the “Court”) issued its highly anticipated advisory opinion on Obligations of States in respect of Climate Change. In a lengthy, unanimous opinion, the Court clarified States’ obligations under international law “to ensure the protection of the climate system and other parts of the environment from anthropogenic…
Status of Section 232 Actions by the Trump Administration
Since taking office in January, President Trump has taken a number of actions under Section 232 of the Trade Expansion Act of 1962 (“Section 232”), a statute that authorizes the President to “adjust” imports—including through application of tariffs, quotas, tariff rate quotas, and license fees—where the Department of Commerce (“Commerce”) determines imports threaten to impair U.S.…
U.S. Food Agencies Issue Joint Request for Information on Ultra-Processed Foods
On July 25, 2025, the Food and Drug Administration (FDA), the Department of Health and Human Services (HHS), and the United States Department of Agriculture (USDA) issued a joint Request for Information (RFI) seeking “data and information to help develop a uniform definition of ultra-processed foods (UPF or UPFs) for human food products in the…