Semiconductors are critical components that form the foundation of virtually all modern technologies and industries, including computers, smartphones, consumer electronics, automobiles, and medical devices. Their global importance continues to grow. This blog provides an overview of recent legal developments in the semiconductor markets of Japan and the United States.

On June 11, 2025, Assistant Attorney General Brett Shumate issued a memorandum to all U.S. Department of Justice Civil Division employees outlining enforcement priorities under directives from President Trump and Attorney General Bondi. The Memorandum signals a shift in federal enforcement focus to issues such as discrimination, gender transition care, and immigration, and identifies the False Claims Act as a tool to achieve certain of the Administration’s goals.  

On June 30, 2025, the Securities and Exchange Commission’s (SEC) Division of Corporation Finance (the Division) revised two and eliminated one of its Compliance and Disclosure Interpretations (C&DIs) related to the disclosure of environmental proceedings under Item 103 of Regulation S-K. These changes updated Questions 105.01 and 105.03 pursuant to the August 2020 modernization of Items 101, 103, and 105. The Division also withdrew its previous guidance that administrative or judicial proceedings arising under “local provisions” in Item 103(c)(3) encompass environmental actions brought by a foreign government.