voluntary disclosure

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By Patrick D. Joyce, Jeryl L. Olson, and Craig B. Simonsen

EPA SignThe U.S. Environmental Protection Agency is modernizing its self-disclosure policy, commonly known as the Audit Policy, through a centralized “eDisclosure Portal” to receive and automatically process self-disclosed civil violations of environmental laws. 80 Fed. Reg. 76476 (December 9, 2015).

The new Portal will serve as…
Continue Reading EPA Modernizes the Audit Policy

By Eric E. Boyd and Jeryl L. Olson

The U.S. Environmental Protection Agency’s (EPA) Office of Enforcement and Compliance Assurance has issued its draft guidance on the Fiscal Year 2013 enforcement program (FY 2013 Draft Guidance). The FY 2013 Draft Guidance identifies EPA’s intent to significantly cut back traditional federal enforcement strategies across all major federal environmental programs, …

Continue Reading U.S. EPA Intends to Slash Federal Enforcement Programs and End Support of Voluntary Disclosures Under its Audit Policy