Procedural Requirements for DOT Enforcement Actions

On March 11, 2025, DOT Acting General Counsel Gregory D. Cote issued a memorandum that clarifies the procedural requirements governing enforcement actions initiated by DOT. The purpose of the memorandum is to ensure that DOT enforcement actions satisfy principles of due process and remain lawful, reasonable and consistent with Administration policy. On May 16, 2025, DOT issued a Notice of Proposed Rulemaking proposing to codify the provisions of the memorandum, along with additional provisions, in the Code of Federal Regulations. DOT has received comments on the Notice of Proposed Rulemaking and is preparing a final rule.

Documents

• Procedural Requirements for DOT Enforcement Actions
• Notice of Proposed Rulemaking on Administrative Rulemaking, Guidance, and Enforcement Procedures