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FinCEN Issues Interim Final Rule – BOI Reporting Obligations Narrowed to Foreign Reporting Companies and New Deadlines Issued

As we previously discussed and in alignment with the U.S. Treasury Department’s previous announcement, on March 21, 2025, the Financial Crimes Enforcement Network (“FinCEN”) issued an interim final rule that dramatically...more

FinCEN and the U.S. Treasury Department Suspend CTA Enforcement – Forthcoming Rule to Narrow CTA Compliance to Foreign Reporting...

On February 27, 2025, the Financial Crimes Enforcement Network (“FinCEN”) announced a suspension of enforcement actions related to the Corporate Transparency Act (“CTA”). This announcement means that reporting companies are...more

Corporate Transparency Act: Once Again Enforceable – New Compliance Dates Apply

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...more

New Administration: Key Energy Issues Tied to Executive Orders

After little more than a week in office, there is still plenty of speculation, but priorities of the Trump 2.0 Administration are becoming more concrete. Issuance of three energy-focused Executive Orders (Unleashing American...more

Supreme Court Grants Stay of Preliminary Injunction Against Corporate Transparency Act – Second Injunction Still In Effect

On January 23, 2025, the Supreme Court granted the government’s motion to stay a nationwide injunction that was issued by a Texas federal judge in the case Texas Top Cop Shop, Inc. v. McHenry. As we discussed previously,...more

DOE Issues LNG Export Study; Public Comment Period Straddles the Upcoming Administration Change

On December 17, 2024, the Office of Fossil and Carbon Management of the Department of Energy (“DOE”) released the long-awaited Liquefied Natural Gas (“LNG”) Export Study (“Study”). The Study was released 11 months after the...more

Fifth Circuit Vacates Stay of Injunction Against Enforcement of the Corporate Transparency Act – Nationwide Preliminary Injunction...

As we previously discussed, on December 5, 2024, the Department of Justice (“DOJ”), representing the Department of the Treasury, submitted a notice of appeal to the U.S. Court of Appeals for the Fifth Circuit, challenging a...more

[CLE Hybrid Event] Outlook on the New Administration - November 19th, Houston, TX

With any new Presidential administration come questions about what will change in terms of policy and law—and how quickly. Join Vinson & Elkins for an insightful program where we will discuss the expectations and procedural...more

The New NEPA Regulations: What You Need to Know About the “Significant Effects” the Final Phase 2 Rule Could Have on Permitting...

On May 1, 2024, the Council on Environmental Quality (“CEQ”) published the final version of Phase 2 of its National Environmental Policy Act (“NEPA”) rulemaking (“Phase 2 Rule”). The Phase 2 Rule is the culmination of the...more

The Corporate Transparency Act - NSBU v. Yellen

In a key development relating to the Corporate Transparency Act (the “CTA”), on March 1, 2024, U.S. District Judge Liles C. Burke of the Northern District of Alabama issued a memorandum opinion and final judgment ruling the...more

Supreme Court Oral Argument in Jarkesy Laser-Focused on Seventh Amendment Trial Right in Agency Civil Penalty Enforcement Actions

On November 29, 2023, the Supreme Court heard oral argument in a critically important administrative law case, Securities and Exchange Commission v. Jarkesy, No. 22-859. This case carries enormous potential consequences for...more

Questions Remain After EPA and the Army Corps Update the “Waters of the United States” Definition Following Sackett v. EPA

On August 29, 2023, the Environmental Protection Agency (“EPA”) and U.S. Army Corps of Engineers (“Corps”) released the text of a rule further revising the definition of “waters of the United States” (“WOTUS”) that the...more

CEQ’s Proposed NEPA Phase 2 Rule Turns Procedure Into Substance and Could Have "Significant Effects" on Permitting and...

Federal agencies are required to conduct assessments under the National Environmental Policy Act (“NEPA”) before taking “major federal actions,” such as granting permits needed for infrastructure projects and for certain...more

Sackett v. EPA: The Supreme Court Clarifies Clean Water Act Jurisdiction

On May 25, 2023, the Supreme Court of the United States issued its decision in Sackett v. EPA, clarifying and narrowing the reach of federal jurisdiction under the Clean Water Act (“CWA”). For decades, confusion has persisted...more

CEQ Releases New Guidance for Assessing Greenhouse Gas Emissions and Climate Change under NEPA

In a move that could have far-ranging implications for projects that require federal permits and rulemaking across the entire federal government, the White House’s Council on Environmental Quality (“CEQ”) published interim...more

Something Old or Something New?: Navigating the Biden Administration’s Latest Move on Defining “Waters of the United States”

The Environmental Protection Agency (“EPA”) and U.S. Army Corps of Engineers (“Army Corps”) delivered on their commitment to issue a new rule defining “waters of the United States” (“WOTUS”) by the end of 2022, releasing a...more

FERC Issues Two New Policy Statements Regarding Natural Gas Infrastructure Construction

On February 18, 2022, the Federal Energy Regulatory Commission (“FERC”) issued two important policy statements by a 3-2 vote related to the construction of natural gas facilities....more

FERC Complicates Natural Gas Infrastructure Application Process

The Federal Energy Regulatory Commission (“FERC”) issued two important policy statements by a 3-2 vote on February 18, 2022 regarding the construction of natural gas facilities. The policy statements make numerous changes to...more

“Immediately Effective” Midnight Rules — Beyond The Hour For Change Or Vulnerable To Court Challenges?

Ordinarily, the law governing how agencies create regulations — the Administrative Procedure Act — requires a thirty-day window between when a rule is published in the Federal Register and becomes “final” and when the rule is...more

Navigating The Transition: Key Infrastructure Issues To Watch In The Biden Administration

Each new presidential administration brings with it its own set of policy goals and priorities. While the text of U.S. environmental law does not change without an act of Congress, agencies within the executive branch have a...more

Navigating The Transition: Key Midstream Issues To Watch In The Biden Administration

News stories and campaign rhetoric frequently create expectations of immediate shifts following an administration change, but most changes in the federal government happen slowly, and the constraint on resources and time...more

Army Corps Finalizes Nationwide Permit Revisions Affecting Infrastructure Development

On January 5, 2021, the U.S. Army Corps of Engineers (“Army Corps”) released a pre-publication version of its final rule reissuing and modifying a subset of its suite of nationwide permits (“NWPs”), including those used for...more

[Webinar] Navigating CFIUS, Export Controls and Sanctions in the Biden Administration - January 21st, 12:00 pm - 1:00 pm CT

Members of V&E’s National Security & International Trade practice discuss recent trade and investment developments and what to expect in the new Administration....more

[Webinar] Power Shift: Regulatory Reform in a Biden Administration - December 9th, 12:00 pm - 1:00 pm CT

President-Elect Joe Biden has promised to change course, including on a number of the Trump Administration’s signature (de)regulatory and executive actions — from energy and the environment to public health, immigration, and...more

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