The Trump Administration’s First 100 Days

April 30, 2025

One hundred days in, it appears that the administration’s policy shifts will continue at a rapid pace.

In this special edition of Insights, we provide analysis of the key changes in important areas including tariffs, tax and government enforcement, and highlight their potential impacts. We also examine the U.S. Supreme Court’s recent actions and the significant questions the Court may soon be asked to address regarding the limits of the executive branch’s powers. 

Antitrust | Energy Projects | Environmental | FDA | SEC | SEC Enforcement | Supreme Court | Tariffs | Tax

Antitrust Enforcers Will Take a Friendlier Approach to Mergers but Retain Biden-Era Guidelines and HSR Rules
The Trump merger enforcers may be more open to mergers and remedies, but they have left the Biden-era Merger Guidelines and HSR filing rules in place, and they are likely to closely scrutinize Big Tech, health care and agriculture deals. 

White House Moves To Encourage Fossil Fuel and Critical Mineral Production
Several executive orders have expanded support for domestic energy resources (with a focus on fossil fuels and critical minerals), declared a national energy emergency, paused Biden-era programs and created the National Energy Dominance Council.

Trump Administration Rolls Back Climate Initiatives and Orders EPA To Set Sunset Dates for Regulations
The first 100 days of the second Trump administration has, for environmental matters, focused on spurring domestic energy production (particularly from fossil fuels) and rolling back existing regulations.

Mass Layoffs at FDA Could Have the Greatest Impact on Products in Development
The layoff of 3,500 FDA employees may have a major impact on drug and device applicants, who are likely to receive less guidance and feedback, and fewer updates on applications. Approval dates may also become less predictable.

SEC Moves Quickly To Create a Regulatory Framework for Cryptocurrencies and Reconsider Its Rules and Guidance
The SEC has abandoned Biden-era climate disclosure rules, reversed prior guidance on shareholder proposals and prioritized the creation of a regulatory framework for cryptocurrencies.

SEC Enforcement Policies Suggest a Return to Basics
The SEC appears poised to narrow its enforcement activity and refocus it on core areas associated with the protection of retail investors, consistent with new Chair Paul Atkins’ vision that the SEC return to “common sense.”

Supreme Court Could Soon Rule on the Merits in Challenges to the Trump Administration
The Supreme Court has largely avoided the merits of challenges to executive authority, but a rare 1 a.m. order granting an emergency stay may signal a growing willingness to address questions about the limits of executive power.

The Tariff Revolution
President Trump’s new tariff regime has upended decades of largely free trade-focused policy consensus in Washington. We look at the state of play and ways that companies can adapt to a volatile trade environment.

Executive and Administrative Changes Shape Tax Policy Ahead of Legislation
Tax policy has become intertwined with tariffs ahead of negotiations over tax legislation. At the same time, the IRS has faced ongoing staff reductions, proposed budget cuts and leadership turnover.

Related Capabilities

Antitrust/Competition // Blockchain and Digital Assets // Climate Change // Energy and Infrastructure Projects // Environmental // Environmental, Social and Governance (ESG) // FDA Regulatory // International Tax // International Trade // Investment Management // Labor and Employment Law // Life Sciences and Health Care // Litigation // Mergers and Acquisitions // National Security // SEC Reporting and Compliance // Securities and Commodities Enforcement // Supreme Court and Appellate Litigation  // Trump Executive Actions Advisory Group // White Collar Defense and Investigations