On May 12, 2025, President Trump signed an Executive Order (“EO” or “Order”) “Delivering Most-Favored-Nation Prescription Drug Pricing to American Patients” aimed at significantly reducing U.S. prescription drug prices by aligning them with the lowest prices paid by other developed nations. According to the EO, drug manufacturers “deeply discount their products to access foreign markets and subsidize that decrease through enormously high prices in the United States.” Seeking to rectify this “egregious imbalance,” the EO announced the following policy: “Americans must therefore have access to the most-favored-nation price for these products… [and] should drug manufacturers fail to offer American consumers the most-favored-nation lowest price, [the] Administration will take additional aggressive action.”
Wynne Leahy
Associate Attorney, Washington, D.C.
+1 202.777.9541
Wynne Leahy is an associate in the Washington, D.C. office of Gibson, Dunn & Crutcher. She practices in the firm’s Litigation Department with a particular focus on white collar defense investigations, food and drug regulatory matters, and complex commercial litigation. Wynne has experience representing multinational companies in investigations conducted by the Department of Justice, the Securities and Exchange Commission, the United States Congress, and other regulatory and enforcement agencies. She has conducted internal investigations involving alleged violations of the Food, Drug, and Cosmetic Act, Anti-Kickback Statute, and False Claims Act.