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In a move that perhaps comes as no surprise, on March 27, 2025, the Securities and Exchange Commission (“SEC” or “the Commission”) issued Press Release 2025-58 announcing it had voted to end its defense of its climate-related disclosures rules (The Enhancement and Standardization of Climate-Related Disclosures for Investors).

On March 14, 2025, President Trump signed legislation disapproving the Environmental Protection Agency’s regulation implementing the Inflation Reduction Act’s tax on methane emissions from the oil and gas sector.

If past is prologue, while the second Trump administration is expected to take a number of actions that could lead to increased volatility with respect to renewable identification number (“RIN”) prices just as the first did, there are signals that the administration may take a more deliberate approach this time to reduce shocks to the RIN market, all the more given the interest in supporting renewable fuel production as a domestic fuel source. And while the California Air Resources Board (“CARB”) took steps last year that impact the ability of biogas projects to generate Low Carbon Fuel Standard (“LCFS”) credits, state legislative headwinds could eventually result in the opening of new environmental credit markets to shore up demand for renewable natural gas (“RNG”). Overall, while significant uncertainty and risk of RIN volatility remains, there continue to be signals from both the federal executive and legislative branches in support of the federal Renewable Fuel Standard (“RFS”).

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.

California continues to ramp up recent efforts to ferret out anticompetitive conduct in the Golden State through oversight and enforcement.

As we previously discussed, on January 7, 2025, the U.S. District Court for the Eastern District of Texas issued a nationwide injunction delaying the implementation of the Corporate Transparency Act’s (“CTA”) reporting requirements (Smith, et al. v. U.S. Department of the Treasury).

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.

On February 10, Vinson & Elkins LLP’s Hill Wellford, co-chair of the firm’s antitrust group, and Kara Kuritz, an antitrust transactional partner, presented a PLI briefing “Antitrust in Transactions.”

Among the drumbeats of rapid pronouncements and policy shifts since January 20, 2025, the Trump Administration recently issued a 180-day pause on new investigations and enforcement actions involving the U.S. Foreign Corrupt Practices Act of 1977, as amended (the “FCPA”), and signaled a coming shift in how the statute will be enforced in the future.

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.

Darren Tucker and Jason Powers discussed recent antitrust developments in the energy sector and what lies ahead for companies in 2025.