New DEAL Act Mandates Investigation of $1M+ Executive Branch Deals with Law Firms in Narrow 3-Month Window

The Disclosure of Engagements with Attorney Law Firms Act of 2025, or the DEAL Act, is short, but it packs a punch aimed directly at the Executive Branch. This bill isn’t focused on broad policy change; it’s a mandate for a highly specific, retrospective investigation into certain deals made between the government and private law firms.

The Million-Dollar Question

Section 2 of the DEAL Act requires the Comptroller General (the head of the Government Accountability Office, or GAO) to issue a report within 180 days of the bill becoming law. This report has one job: to investigate whether specific "settlements" made between the Executive Branch and a "covered law firm" violated existing federal laws regarding the use of public funds (specifically, section 3302(b) of title 31, U.S. Code).

Here’s where it gets interesting—and highly specific. The investigation is limited to deals made during a very narrow three-month window: February 1, 2025, through April 30, 2025. Furthermore, the deal must involve legal services valued at over $1,000,000.

The Quid Pro Quo Trigger

This isn't about auditing every contract; it targets arrangements that look suspiciously like a regulatory favor in exchange for legal help. A "settlement" is covered if it meets four key criteria, which essentially define a potential quid pro quo arrangement. The law firm must have agreed to provide legal services (even pro bono, or free legal work) for causes or people that the Executive Branch picked or approved.

Crucially, this arrangement must have happened at the same time the Executive Branch decided to pull back, cancel, or simply not enforce a regulatory threat that was aimed at that specific law firm. Think of it this way: if a law firm was facing a potential fine or investigation from a federal agency, and suddenly that agency backed off right after the firm agreed to take on a major pro bono case the White House liked, that deal would trigger this investigation.

Who This Impacts

For the average person, this bill might sound like inside-baseball, but it’s about government accountability. If the GAO finds evidence that the Executive Branch traded regulatory relief for favorable legal work, it exposes potential misuse of government power. That’s a win for transparency.

However, the highly targeted nature of this bill raises eyebrows. By focusing on a specific three-month period—and requiring the coincidence of regulatory relief and a large pro bono agreement—it suggests the investigation is aimed at specific political actions rather than establishing broad, consistent oversight. Law firms that engage in large-scale pro bono work favored by the government during that window, even if fully legitimate, could face high-cost audits and reputational risk. This could potentially chill firms from offering free legal services to government-supported causes if they fear becoming the subject of a politically charged investigation.