Investigations, Enforcement, & Compliance Alerts

On January 27, 2025, the White House published Memorandum M-25-13, titled “Temporary Pause of Agency Grant, Loan, and Other Financial Assistance Programs.” In an unprecedented move, the initial Memo appeared to suspend all funding for all federal grants, cooperative agreements, noncash contributions or donations of property, direct appropriations, food commodities, other financial assistance, loans, loan guarantees, interest subsidies, and insurance that may be implicated by his executive orders. Amidst a national outcry in response to the memorandum, OMB released a subsequent Memorandum on January 28, 2025, in which OMB appeared to walk back the broad freeze on most federal financial assistance. We summarize here the details of the Memos well as the rights and remedies of recipients that may be affected by this action.