Regulatory Reform

11

Digital Assets

2

Due Process

1

AI

1

Fintech

3

Global Investment

2

5/9/25

14295

90 FR 20367

• Orders a reduction in publication delays at the Federal Register to facilitate the President’s deregulation goals.

• The practical effect of this EO would cause more rapid reform as interim final rules (among other changes) are effective immediately upon publication in the Federal Register.

Regulatory Reform

5/9/25

14294

90 FR 20363

• Instructs federal agency heads to report to OMB and post on federal agency websites a list of the criminal offenses and penalties that the federal agency has codified in regulation.

• Establishes a policy against strict liability criminal regulatory offenses.

• Instructs agency heads to examine statutory authorities and determine whether there is authority to adopt a background mens rea standard for criminal regulatory offenses that would apply unless a specific regulation states an alternative mens rea. Also instructs the agency heads to present a justification for each offense which the agency proposes to deviate from its default mens rea standard.

Regulatory Reform

4/24/2025

14284

90 FR 17729

• Requires agency heads to certify in writing that the continued employment of an individual serving a probationary or trial period will advance the public interest before finalizing appointment to Federal service.

• Instructs Director of OPM to publish a rule rescinding subpart H of part 315 of title 5, Code of Federal Regulations, within 30 days

Regulatory Reform

4/9/25

14267

90 FR 15629

• Instructs federal agency heads to review all regulations subject to their rulemaking authority and analyze those that create barriers to entry for new market participants.

• While not specific to financial services, this includes fintechs and de novo bank formation.

• Instructs agency heads to provide a list of regulations to FTC Chairman and Attorney General.

• Instructs FTC Chairman and Attorney General to issue a request for information that seeks public input on identifying such anti-competitive regulations.

Regulatory Reform, Fintech

3/31/25

14255

90 FR 14899

• Establishes the Investment Accelerator within the Department of Commerce, designed to facilitate investments above $1 billion in the United States.

• Instructs the Investment Accelerator to reduce regulatory burdens where consistent with applicable law, increase access to and use of U.S. national resources where appropriate and consistent with applicable law, facilitate research collaborations with U.S. national labs, and work with State governments in all 50 States to reduce regulatory barriers to, and increase, domestic and foreign investment in the United States.

• While not specific to financial services, this may present opportunities for non-U.S. banks and fintechs to invest in U.S. banks and the financial services sector more broadly.

Global Investment, Fintech

3/25/25

14249

90 FR 14011

• Instructs the Secretary of the Treasury, in consultation with the Director of the Office of Management and Budget, to update guidance and enhance systems to ensure that all payments made by the government are subject to pre-certification verification processes established by the Secretary of the Treasury and conducted by agencies and the Department of the Treasury to combat fraud.

• Agencies must cooperate with the Secretary of the Treasury to fulfill their obligations to determine payment or award eligibility through pre-certification and pre-award procedures.

• Within 90 days (June 2025) of the date of the order, agency heads must review and modify, as applicable, their relevant system of records notices under the Privacy Act of 1974 to include a “routine use” that allows for the disclosure of records to the Department of the Treasury for the purposes of identifying, preventing, or recouping fraud and improper payments, to the extent permissible by law.

For additional commentary, see DWT Alert:
The Future of Government Payments – No More Paper Checks Later This Year

Regulatory Reform

3/25/25

14247

90 FR 14001

• Requires the elimination of paper checks for government disbursements including for intragovernmental payments, benefits payments, vendor payments, and tax refunds, by September 30, 2025.

• Requires any payments to the federal government to be made electronically as soon as practicable, to the extent permitted by law.

For additional commentary, see DWT Alert:
The Future of Government Payments – No More Paper Checks Later This Year

Regulatory Reform

3/6/2025

14233

90 FR 11789

• Establishes "Strategic Bitcoin Reserve" and "United States Digital Asset Stockpile," under the control of the Department of Treasury, capitalized respectively with all Bitcoin and other digital assets held by the Department of Treasury that were forfeited as part of criminal and civil asset forfeiture proceedings or in satisfaction of a civil money penalty imposed by an executive department or agency.

• Directs Secretary of Treasury and Secretary of Commerce to develop strategies for acquiring additional Government Bitcoin.

• Prohibits agency heads from selling or disposing of Government Bitcoin and Stockpile Assets, unless otherwise directed or required by law.

Digital Asset

2/19/2025

Ensuring Lawful Governance and Implementing the President's "Department of Government Efficiency" Deregulatory Initiative

14219

90 FR 10583

• Directs agency heads to examine and provide to OIRA Administrator lists of regulations they administer that may have legal or constitutional flaws so that they may be considered for modification or rescission.

• Directs agency heads to de-prioritize and terminate enforcement actions that do not comply with the Constitution, law, or Administration policy.

• Directs agency heads to consult with DOGE Team Leads and OIRA Administrator on potential new regulations as soon as practicable.

For additional commentary, see DWT Alert:
A New and Demanding Process of Regulatory Analysis and Reduction – Asserting the Unitary Executive (Part II)

Regulatory Reform

2/18/2025

Ensuring Accountability for All Agencies

14215

90 FR 10447

• Requires that independent regulatory agencies submit for review all proposed and final significant regulatory actions to OIRA before publication in the Federal Register.

• Directs the OMB Director to establish performance standards and management objectives for independent agency heads and periodically report to the President on their performance and efficiency with respect to those objectives.

• Directs the OMB Director to conduct ongoing reviews of independent agencies' obligations for consistency with Administration policies and priorities and adjust agencies' apportionments as necessary and appropriate to advance them.

• Requires independent agency heads to regularly consult with and coordinate policies and priorities with the directors of OMB, the White House Domestic Policy Council, and the White House National Economic Council, establish a position of White House Liaison, and submit agency strategic plans to the OMB Director for clearance prior to finalization.

• Restrains agency personnel from adopting legal positions in regulations, guidance, and litigation that contravene interpretations set forth by the President or the Attorney General unless authorized to do so by them.

For additional commentary, see DWT Alert:
Trump's Executive Order on Independent Agencies—and Asserting the Unitary Executive (Part I)

Regulatory Reform

2/11/2025

Implementing The President's "Department of Government Efficiency" Workforce Optimization Initiative

14210

90 FR 9669

• Requires that agencies hire no more than one employee for every four employees that depart.

• Requires agency heads to consult with DOGE Team Leads on new career appointments.

• Directs agency heads to undertake preparations to initiate large-scale reductions in force.

• Directs agency heads to submit to OMB Director report that discusses whether the agency or any of its subcomponents should be eliminated or consolidated.

Regulatory Reform

2/3/2025

A Plan for Establishing a United States Sovereign Wealth Fund

14196

90 FR 9181

• Directs Secretary of Treasury and Secretary of Commerce, in coordination with the Assistant to the President for Economic Policy, to develop and submit to the President a plan for the establishment of a sovereign wealth fund, with recommendations for funding mechanisms, investment strategies, fund structure, and governance model.

Global Investment

1/31/2025

Unleashing Prosperity Through Deregulation

14192

90 FR 9065

• Requires that for each new regulation proposed, at least 10 existing regulations must be eliminated to offset the costs.

• Sets a cap on the total incremental cost of new regulations for fiscal year 2025, requiring that these costs be significantly reduced.

• Directs agencies to identify cost-saving measures and streamline the regulatory process, with the goal of fostering economic growth, improving global competitiveness, and enhancing quality of life while ensuring national security.

Regulatory Reform

1/23/2025

Strengthening American Leadership in Digital Financial Technology

14178

90 FR 8647

• Establishes the President's Working Group on Digital Asset Markets within the National Economic Council.

• The Working Group chaired by the White House Special Advisor for AI and Crypto.

• Separately appointed David Sacks White House A.I. & Crypto Czar.

Requires:
• Within 30 days (Feb. 2025), Treasury, DOJ, and the SEC, as well as other relevant agencies, must identify all regulations, guidance, documents, orders, or other items that affect the digital asset sector.
• Within 60 days (March 2025), each agency must submit their recommendations to the Working Group with respect to whether each identified regulation, guidance document, order, or other item identified should be rescinded or modified or for items other than regulations, adopted in a regulation.
• Within 180 days (July 2025), the Working Group must submit a report to the President recommending regulatory and legislative proposals that "advance the policies established in this Order."

• Prohibits the establishment of Central Bank Digital Currencies.

For additional commentary, see DWT Alert:
Trump Administration Transforms U.S. Policy on Digital Assets

Digital Assets, Fintech

1/23/2025

Removing Barriers to American Leadership in Artificial Intelligence

14179

90 FR 8741

• Revokes certain existing AI policies and directives that act as barriers to AI innovation to retain global leadership in AI.

• Directs the development of an AI action plan within 180 days.

AI

1/20/2025

Initial Rescissions Of Harmful Executive Orders And Actions

14148

90 FR 8237

• Revokes 78 orders from the Biden Administration and thereby reinstates several actions and orders from the first Trump Administration.

Including:
• EOs 13771, 13893 and 13979, which limited the regulatory state and required more thorough review of proposed regulations.

• EO 13777, which requires each agency head to designate a Regulatory Reform Officer and establish a Regulatory Task Force within each agency.

For additional commentary, see DWT Alert(s):
Trump's Executive Order on Independent Agencies—and Asserting the Unitary Executive (Part I)

The Executive Branch, Schedule F, and Other Tools To Cabin Administrative Discretion

How Revived Executive Orders Could Limit the Administrative State

Regulatory Reform

1/20/2025

Restoring Accountability To Policy-Influencing Positions Within the Federal Workforce

14171

90 FR 8625

• Reinstates an employee classification called Schedule F, adopted but not implemented during Trump's first administration.
• Schedule F designation was created to make it easier to remove federal workers from positions that are typically apolitical and protected by civil service rules.

For additional commentary, see DWT Alert:
The Executive Branch, Schedule F, and Other Tools To Cabin Administrative Discretion

Due Process