One hesitates to use the word “impunity” casually, since it carries a certain Latin gravity that American political discourse tends to metabolize into shrugging. But Public Citizen’s new accounting of the first year of Trump’s second term leaves the careful reader little choice: 205 corporations, by the report’s count, have had enforcement actions inherited from the Biden administration simply canceled. Not litigated and lost. Not settled at a discount. Canceled, the way one cancels a subscription.
The composition of the retreat is, in the sociological sense, legible. Eighty closed investigations, ten of them criminal. Sixty-seven dismissed enforcement lawsuits, ten of those also criminal. Fifty-four “canceled consequences,” a phrase that should trouble anyone who has ever taught an intro course on deterrence, including fourteen pardons of corporations or executives and five terminated corporate leniency deals. The sectors that benefited most were banking and finance (51 corporations), technology (28), and cryptocurrency and fintech (26). One notes, with the weariness of someone who has read this literature before, that these are precisely the sectors with the deepest lobbying footprints and the most intimate financial ties to the administration. Public Citizen’s companion analysis, using a stricter methodology, puts the figure at 145 canceled actions against 153 corporations, many with lobbying or personal connections to Trump himself. When two counts disagree, the honest scholar reports both; when both counts describe the same directional collapse, the disagreement is a rounding error on the way down.
The mechanism is not mysterious, and this is where I would gently complicate the standard progressive outrage, and then complicate the complication. The popular framing is corruption, a quid pro quo, a favor economy. Some of that is no doubt present. But the deeper story is doctrinal. Consider the Amazon case: the EEOC had sued the company for allegedly discriminating against pregnant workers. In April 2025, Trump signed an executive order directing agencies to stop relying on disparate impact analysis, the statistical framework through which structural discrimination is actually provable, and the lawsuit was subsequently dismissed. That is not a bag of cash changing hands in a parking garage. That is the deliberate dismantling of the evidentiary architecture that makes enforcement possible at all. Remove the instrument, and the cases dismiss themselves. It is elegant, in the way that things engineered to be unaccountable tend to be.
Rick Claypool, the report’s author and a research director at Public Citizen, put it plainly: the retreat signals that “if you’re big enough, rich enough, and connected enough with Trump’s inner circle, there are no consequences for breaking the law.” He connects the message to observable outcomes, the reckless experiments of AI firms, proliferating financial fraud, tainted food outbreaks. The deterrence literature, which I will spare you the citations for, has been consistent on this point for half a century: enforcement that is visible and certain deters; enforcement that is visibly purchasable does the opposite, and does it efficiently.
The complication of the complication, then, is this: the administration’s defenders will say it is merely “rebalancing” an overzealous regulatory state, and they will be wrong, but not entirely without a rhetorical foothold, because public trust in regulatory institutions was already eroded before anyone canceled anything. The tragedy is not that the system was perfect and is being broken. It is that the system was the only one we had, and it is being broken by the very actors it was built to constrain, with the blessing of a judiciary and a Congress that have largely stopped asking questions.
Two hundred and five corporations now operate in a regulatory environment best described as aspirational. The literature on what happens next is short, because we have never run this experiment at this scale. We are running it now.