Tag: self-disclosure

DOJ’s Updated Voluntary Self-Disclosure Policy

In March 2023, the Environmental Crimes Section (ECS) of the U.S. Department of Justice (DOJ) Environment and Natural Resources Division (ENRD) issued revisions to its Voluntary Self-Disclosure (VSD) Policy. The revisions set forth: Standards for what constitutes a VSD of misconduct to the ECS, A description of benefits ECS prosecutors will confer on companies that […]

EPA sign, Environmental Protection Agency

A Look at EPA’s Audit Policy and Voluntary Self-Disclosure

On February 5, 2021, the EPA posted updated Frequently Asked Questions (FAQs) for its Audit Policy, formally titled “Incentives for Self- Policing: Discovery, Disclosure, Correction and Prevention of Violations.” This policy provides incentives, such as penalty waivers, for regulated entities to prevent, discover, disclose, and correct environmental violations on a voluntary basis.

A Look at the EPA’s Audit Policy and Self-Disclosure

On March 26, 2020, the EPA’s Office of Enforcement and Compliance Assistance (OECA) issued a temporary enforcement discretionary policy due to the COVID-19 pandemic. Generally, the policy states that “regulated entities should make every effort to comply with their environmental compliance obligations,” but the EPA does not expect to seek penalties for violations of routine compliance […]