Paul Freeman

Partner

Overview

Paul Freeman is a partner in Crowell & Moring’s New York office and a member of the firm’s Environment and Natural Resources and Government Contracts groups. He brings two decades of diverse experience advising clients in the energy, maritime, and aerospace and defense industries on a range of issues, with a primary emphasis on matters involving enforcement defense, litigation, and risk management.

Paul routinely advises clients in response to investigations by, or inquiries from, a range of regulators, primarily the U.S. Environmental Protection Agency (EPA) and the U.S. Department of Justice (DOJ), and also including the U.S. Securities and Exchange Commission, the Internal Revenue Service, the U.S. Department of Defense Inspector General, the Federal Bureau of Investigation, the U.S. Commodity Futures Trading Commission, and state attorneys general.
 
Over the past several years Paul has represented a wide range of fuel suppliers, commodities traders, and other market participants in matters arising under the federal Renewable Fuel Standard (RFS) program, including the RFS Quality Assurance Program and the ongoing representation of clients currently confronting enforcement by EPA and DOJ under the RFS regime. 

Extending his risk management and investigations practice across multiple industrial sectors, Paul also counsels Fortune 50 defense contractors on compliance with aspects of the Federal Acquisition Regulation (FAR), including the mandatory disclosure rule, and he routinely conducts internal investigations involving supply chain risks, ethics, quality systems, contract compliance, and potential false claims.

Prior to joining Crowell & Moring, Paul was counsel at a major global law firm.

Career & Education

    • Environmental Protection Agency
      Office of General Counsel Honors Program, 1997
    • Environmental Protection Agency
      Office of General Counsel Honors Program, 1997
    • Vermont Law School, M.S.E.L., cum laude, 2001
    • Vermont Law School, J.D., 1998
    • St. Lawrence University, B.A., cum laude, 1995
    • Vermont Law School, M.S.E.L., cum laude, 2001
    • Vermont Law School, J.D., 1998
    • St. Lawrence University, B.A., cum laude, 1995
    • New York
    • Connecticut
    • District of Columbia
    • U.S. District Court for the Eastern District of New York
    • U.S. District Court for the Southern District of New York
    • U.S. District Court for the District of Connecticut
    • New York
    • Connecticut
    • District of Columbia
    • U.S. District Court for the Eastern District of New York
    • U.S. District Court for the Southern District of New York
    • U.S. District Court for the District of Connecticut

Paul's Insights

Client Alert | 4 min read | 09.16.25

EPA Seeks Vacatur of Majority of Biden-Era PFAS Regulations under the Safe Drinking Water Act - A Sign of More to Come?

On September 11, 2025, the Environmental Protection Agency (EPA) asked the D.C. Circuit to vacate regulations for four types of polyfluoroalkyls (known collectively as “PFAS”) in drinking water. The motion for partial vacatur marks a significant reversal in the agency’s policy, as the EPA had previously vigorously defended legal challenges to the first-of-their-kind standards in federal court for the past two years. See American Water Works Association, et al. v. EPA, case no. 24-1188 and consolidated cases (D.C. Cir. filed June 7, 2024). Just this month, the case was given the green light to proceed, after being held in abeyance (at the request of both parties) so that the Trump administration could determine how it wished to proceed. The change signals a willingness on the part of the administration to act on previously issued non-legally binding announcements of forthcoming changes to Biden-era rules and may also serve as a harbinger for how the new administration will tackle PFAS under other statutes, such as the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA)....

Recognition

  • Law360: Practice Group of the Year – Government Contracts, 2019

Paul's Insights

Client Alert | 4 min read | 09.16.25

EPA Seeks Vacatur of Majority of Biden-Era PFAS Regulations under the Safe Drinking Water Act - A Sign of More to Come?

On September 11, 2025, the Environmental Protection Agency (EPA) asked the D.C. Circuit to vacate regulations for four types of polyfluoroalkyls (known collectively as “PFAS”) in drinking water. The motion for partial vacatur marks a significant reversal in the agency’s policy, as the EPA had previously vigorously defended legal challenges to the first-of-their-kind standards in federal court for the past two years. See American Water Works Association, et al. v. EPA, case no. 24-1188 and consolidated cases (D.C. Cir. filed June 7, 2024). Just this month, the case was given the green light to proceed, after being held in abeyance (at the request of both parties) so that the Trump administration could determine how it wished to proceed. The change signals a willingness on the part of the administration to act on previously issued non-legally binding announcements of forthcoming changes to Biden-era rules and may also serve as a harbinger for how the new administration will tackle PFAS under other statutes, such as the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA)....

Paul's Insights

Client Alert | 4 min read | 09.16.25

EPA Seeks Vacatur of Majority of Biden-Era PFAS Regulations under the Safe Drinking Water Act - A Sign of More to Come?

On September 11, 2025, the Environmental Protection Agency (EPA) asked the D.C. Circuit to vacate regulations for four types of polyfluoroalkyls (known collectively as “PFAS”) in drinking water. The motion for partial vacatur marks a significant reversal in the agency’s policy, as the EPA had previously vigorously defended legal challenges to the first-of-their-kind standards in federal court for the past two years. See American Water Works Association, et al. v. EPA, case no. 24-1188 and consolidated cases (D.C. Cir. filed June 7, 2024). Just this month, the case was given the green light to proceed, after being held in abeyance (at the request of both parties) so that the Trump administration could determine how it wished to proceed. The change signals a willingness on the part of the administration to act on previously issued non-legally binding announcements of forthcoming changes to Biden-era rules and may also serve as a harbinger for how the new administration will tackle PFAS under other statutes, such as the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA)....