Skip to content

menu

Greenberg Traurig, LLP logo
HomeContact UsEuropeAsiaLatin AmericaEnvironmentalEnergy
Search
Close

E2 Law Blog

Insights and Commentary on Global Environmental and Energy Issues

Home » DOJ’s Updated Corporate Crime Policies: Practical Considerations in the Environmental Context

DOJ’s Updated Corporate Crime Policies: Practical Considerations in the Environmental Context

Environment protection concept Renewable energy Sustainable development goals SDGs-Shutterstock_1746975767
By Steven C. Russo, Christopher Bell, Sylvia Simson & Mike Mirdamadi on October 3, 2022
Posted in Compliance, DOJ, Environmental Social & Governance (ESG), EPA, Featured, Federal, GT Alert, Risk management

The 2022 Monaco Memo highlights two “core principles” regarding voluntary self-disclosure. First, absent aggravating factors, DOJ will not “seek a guilty plea when a company has voluntarily self-disclosed, cooperated, and remediated misconduct.” Second, DOJ will not “require the imposition of an independent compliance monitor” if the company has implemented and tested an effective compliance program by the time of any resolution between the company and DOJ.

Continue reading the full GT Alert.

Tags: corporate crime, corporate governance, Department of Justice, DOJ, Environmental Protection Agency, Environmental Social and Corporate Governance, EPA, GT Insight, monitorship
Print:
Email this postTweet this postLike this postShare this post on LinkedIn
Photo of Steven C. Russo Steven C. Russo

Steven C. Russo co-chairs the Environmental Practice and chairs the firm’s New York Environmental Practice. He focuses his practice on environmental law and litigation, permitting, National Environmental Policy Act (NEPA), State Environmental Quality Review Act (SEQRA) review, energy project siting, renewable energy, Brownfields

…

Steven C. Russo co-chairs the Environmental Practice and chairs the firm’s New York Environmental Practice. He focuses his practice on environmental law and litigation, permitting, National Environmental Policy Act (NEPA), State Environmental Quality Review Act (SEQRA) review, energy project siting, renewable energy, Brownfields redevelopment, toxic tort litigation, including emerging contaminants, environmental crimes, government law and policy and the environmental review and permitting, environmental due diligence and risk management, and the environmental components of land use and real estate law. Steven is equally experienced litigating in federal and state courts, as well as counseling his clients with regard to the development of major industrial, energy and residential development projects. He also practices election and campaign finance law.

Prior to joining the firm, Steven was the Chief Legal Officer of the New York State Department of Environmental Conservation. There, he supervised approximately 90 attorneys in Albany, as well as the agency’s nine regional offices. He also supervised the agency’s legislative affairs department and Office of Environmental Justice. At the agency, Steven initiated a reform of the state’s environmental impact review regulations and assessment forms, completed the issuance of new power plant siting regulations pertaining to environmental justice and carbon emissions, and revised the agency’s environmental audit policy.

Read more about Steven C. Russo
Show more Show less
Photo of Christopher Bell Christopher Bell

Chris Bell represents clients in civil and criminal enforcement and investigations, litigation, compliance counseling, emergency incident response, and legislative and regulatory advocacy (including appellate challenges to rulemakings) under all of the major environmental, health, safety and natural resource laws. His enforcement experience includes…

Chris Bell represents clients in civil and criminal enforcement and investigations, litigation, compliance counseling, emergency incident response, and legislative and regulatory advocacy (including appellate challenges to rulemakings) under all of the major environmental, health, safety and natural resource laws. His enforcement experience includes internal investigations, responding to grand jury investigations and agency information requests, and negotiating consent, probation, and debarment agreements. He is currently the EPA Independent Monitor overseeing the nation’s largest investor-owned energy company’s compliance with complex debarment and probation agreements arising from the resolution of a criminal enforcement case brought under the Clean Water Act.

Chris assists buyers, sellers, investors and financial institutions on the environmental aspects of transactions, including conducting due diligence, negotiating the environmental provisions of transactional documents, and identifying and executing insurance-based risk management opportunities. His transactional experience has included upstream, midstream and downstream energy projects, alternative energy projects, and transactions in the manufacturing, logistics, consumer products and chemicals sectors.

He helps clients evaluate and implement compliance and ethics programs (e.g., under the Sentencing Guidelines), and environmental, health and safety management systems (including based on ISO 14001). Chris advises clients on sustainable development, climate change, product and chemical stewardship and regulation, and value chain management. He recently served on an independent committee advising the senior management of a Fortune 50 company on its global sustainability strategy and reporting.

Read more about Christopher Bell
Show more Show less
Photo of Sylvia Simson Sylvia Simson

Sylvia Simson, a shareholder in GT’s New York office, is a litigator with a diverse practice focused on a broad range of complex commercial litigation as well as mass torts/products liability, financial services, life sciences, and environmental matters.  Ms. Simson is experienced both

…

Sylvia Simson, a shareholder in GT’s New York office, is a litigator with a diverse practice focused on a broad range of complex commercial litigation as well as mass torts/products liability, financial services, life sciences, and environmental matters.  Ms. Simson is experienced both in trials and appeals and has deep experience with multi-district litigation, class action defense, and the coordination of related actions in different jurisdictions.

Ms. Simson has counseled global and national corporations and institutions, mid-sized or privately-held companies, partnerships, start-up entities, and individuals in both federal and state cases across the country.  The matters she has litigated concern a variety of issues, including contractual disputes (with specific expertise on those governed by New York or Delaware law), disputes arising out of M&A transactions, alleged fraud and/or breach of fiduciary duty claims, purported product defects, failure to warn allegations, false advertising and deceptive trade practices claims, business torts, bankruptcy, financial products, insurance coverage, purported toxic exposure claims (involving various forms of chemicals or dust as well as asbestos), various environmental statutes and regulations, and alleged False Claims Act violations.  Her experience also spans a wide range of industries, including the consumer products, pharmaceutical/medical device, financial services, energy, chemicals, technology, insurance, building materials, and fashion, beauty, and luxury goods sectors.

Read more about Sylvia SimsonSylvia's Linkedin Profile
Show more Show less
Photo of Mike Mirdamadi Mike Mirdamadi

Michael E. Mirdamadi represents clients in a broad range of high-stakes commercial and securities litigation matters in federal and state courts across the country. He has deep experience in all phases of civil litigation, on both the plaintiff and defense side and at

…

Michael E. Mirdamadi represents clients in a broad range of high-stakes commercial and securities litigation matters in federal and state courts across the country. He has deep experience in all phases of civil litigation, on both the plaintiff and defense side and at both the trial and appellate level. Mike also has experience representing clients in internal and government investigations, regulatory enforcement actions, and other compliance and white collar matters.

Read more about Mike MirdamadiMike's Linkedin Profile
Show more Show less
Related Posts
Environmental_Proposal
Environment, Energy, and Resources Law: The Year in Review 2021
July 18, 2022
Environmental-justice-scales (1)
New Lawsuit Challenges DOJ Policy Prohibiting SEPs
October 14, 2020
Smokestack in factory with yellow sky and clouds. Industrial pollution.
June 8 Webinar: EU Carbon Border Adjustment Mechanism (CBAM) Regulation
June 6, 2023

Stay Connected

Subscribe to this blog via RSS Follow GT on Twitter Join the Discussion on Facebook View GT's LinkedIn Profile
Subscribe

Listen to our E2 Law Podcast for insights and commentary on global environmental and energy issues.

  Announcements

  • GT’s Environmental Practice Recognized in 2025 Chambers USA Guide
  • GT’s Energy & Natural Resources Practice Recognized in 2025 Chambers USA Guide

About Us

GT’s Environmental Practice is one of the largest and geographically broadest environmental groups of any law firm based in the United States. Our client-focused, problem-solving approach reflects the commitment to service that has led major national companies in a variety of industry segments.

Read More....

Blog Authors Show/Hide

  • Lindsay N. Aherne
  • Jorge Aleman Juarez
  • Benjamin Almy ‡
  • Mary Katherine Andrews
  • Luis Jorge Akle Arronte
  • Greenberg Traurig
  • Nicholas T. Barnes
  • Steven Barringer
  • Kerri Barsh
  • Christopher Bell
  • Sean W. Bezark
  • Marijn Bodelier
  • Marijn Bodelier
  • Kara M. Bombach
  • Nicolas Borda
  • Martin Borning
  • Lynelle Bosworth
  • Laura Bottaro
  • Zachary W. Branson
  • Cyril T. Brennan
  • Thomas R. Brill
  • Tarik A. Brooks
  • Keyon Brown
  • Caitlyn E. Jones
  • Michael P. Canavan
  • Deirdre A. Carson
  • Greenberg Traurig
  • Rubén Alejandro Ortiz Cervera
  • Jeffrey A. Chester
  • John V. Chibbaro
  • Jacomijn Christ
  • Frank Citera
  • Andrew B. Claytor ‡
  • Joshua Cohen
  • Michael Cooke
  • Travis Coon
  • Greenberg Traurig, LLP
  • Paula Maria De Uriarte ˘
  • Sonali Dohale
  • Tim Dolan
  • Arthur Don
  • Julie P. Dostal
  • Craig Duewall
  • Hayley Easton
  • Daniel G. Egers
  • Troy A. Eid
  • Robert C. Epstein
  • Paolo Esposito
  • Daniel P. Filor
  • Rodolfo Flores-Urquiza Sosa
  • Luigi Fontanesi
  • Robert Freund
  • John Gao
  • Maria C. Garcia˘
  • Samuel Garcia Nelen
  • William Garner
  • Brian Gaudet
  • Jack Gearan
  • David Gillespie
  • Juan Manuel González Bernal
  • Nancy Guillén Espinosa
  • Ellen M. Gustafson
  • Jennifer M. Gómez
  • Hamilton Hackney III
  • Caitlyn E. Haller
  • Dr. Martin Hamer
  • Robert Hardy
  • Candace Headen Uduebor
  • Greenberg Traurig
  • Genus Heidary
  • Laura Hendee
  • Jeffry M. Henderson
  • Elizabeth B. Herdes
  • Jan Herfkens
  • Erick Hernández Gallego
  • Rob Herrington
  • Edward S. Hershfield
  • Tom Hilton ˘
  • Caleb Holmes
  • Richard Hughes
  • William Hurst
  • Ayshan E. Ibrahim
  • David C. Jense
  • Barbara A. Jones
  • Laura E. Jones
  • Sandra K. Jorgensen
  • Todd Kaminsky
  • Barbara T. Kaplan
  • Harris L. Kay
  • Jairo Keeldar ˘
  • Julie Kendig-Schrader
  • Greenberg Traurig, LLP
  • Alice Kessler
  • Harshita Khurana‡
  • Joseph Kim
  • Marvin A. Kirsner
  • Aaron S. Klein
  • Zackary D. Knaub
  • Natalie Kopplow
  • Shashank Krishna
  • Joanna Kuc
  • Christopher M. LaVigne
  • James O. Lang
  • Ester Latorre
  • Gregory K. Lawrence
  • Ashley LeBlanc
  • Jack LeBris Erffmeyer
  • Thomas O. Lemon
  • Lauren A. Liss
  • Alexandra “Ally” Lizano
  • David Mandelbaum
  • Robert Mangas
  • John L. Mascialino
  • Kaitlyn R Maxwell
  • Harriet McConnell
  • Terrence P. McCourt
  • Paul R. McIntyre
  • Jane McLaughlin
  • Graeme McLellan
  • Peter Mezey
  • David I. Miller
  • Kenneth M. Minesinger
  • Mike Mirdamadi
  • Agustin Mora Bowen
  • Samuel L. Moultrie
  • Greenberg Traurig, LLP
  • Michael G. Murphy
  • Edwin J. Nazario
  • Samir NeJame
  • Howard L. Nelson
  • Christopher J. Neumann
  • Daniell K. Newman
  • Glenn Newman
  • Grant E. Nichols
  • Maribel Nicholson-Choice
  • Molly K. O'Neil
  • Hazel Ocampo
  • Madeline Orlando
  • Pablo Ortiz Mena Montes de Oca
  • Rocco Pallin˘
  • Evan Preminger
  • Arturo Pérez-Estrada
  • Laura Siegel Rabinowitz
  • Jenna Rackerby
  • Jared Raleigh
  • Bernadette M. Rappold
  • Katie P. Reed˘
  • Greenberg Traurig, LLP
  • Pedro Javier Reséndez Bocanegra
  • Craig V. Richardson
  • Adam Roseman
  • Robert M Rosenthal
  • Marc M. Rossell
  • Andrew P. Rubin
  • LaQuenta C. Rudison
  • Shivani Rumalla
  • Steven C. Russo
  • Alessio Gerhart Ruvolo
  • Doreen U. Saia
  • Hector D. Sanchez Fernandez
  • Monisha Sardjoe
  • Andrew W. Scher
  • Sabine Schoute
  • Paul M. Seby
  • Cate Sharp
  • Courtney M. Shephard
  • Casey A. Shpall
  • Sylvia Simson
  • Kayli D. Smendec
  • Keith E. Smith
  • Greg Sperla
  • Andrew Spielman
  • Meital Stavinsky
  • Libretta Stennes
  • Meiyanne Sturm ˘
  • Tim Swickard
  • Michael Taylor ‡
  • Robert S. Thompson IV
  • Christopher Thorne
  • Matthew K. Tieslau
  • Curtis B. Toll
  • Christopher Torres
  • Rodrigo Vazquez del Mercado-Rivera
  • Marlis Vázquez Egli
  • Eric Waeckerlin
  • Will Wagner
  • Margaret J. Weil
  • Philip R. Weingold
  • David B. Weinstein
  • Lilian Welling-Steffens
  • Christopher R. White
  • William Wu
  • Dawn Zhang
  • Erik de Bie
  • Marie-José van der Heijden

TOPICS

ARCHIVES

Recent Posts

  • GT’s Environmental Practice Recognized in 2025 Chambers USA Guide
  • GT’s Energy & Natural Resources Practice Recognized in 2025 Chambers USA Guide
  • House Proposes Cutbacks to Clean Energy Tax Credits
  • Landmark Supreme Court Decision Limits NEPA Review Scope: Agencies Granted ‘Substantial Deference’ in Environmental Assessments
  • Interior Department Seeks Public Input on Repealing Public Lands and Natural Resources Rules
GT Law Blogs

E2 Law Blog

Greenberg Traurig, LLP logo
Subscribe to this blog via RSS Follow GT on Twitter Join the Discussion on Facebook View GT's LinkedIn Profile
Privacy PolicyDisclaimer

Greenberg Traurig, LLP has more than 2,850 attorneys across 49 locations in the United States, Europe, the Middle East, Latin America, and Asia. The firm’s broad geographic and practice range enables the delivery of innovative and strategic legal services across borders and industries. Recognized as a 2025 BTI “Best of the Best Recommended Law Firm” by general counsel for trust and relationship management, Greenberg Traurig is consistently ranked among the top firms on the Am Law Global 100, NLJ 500, and Law360 400. Greenberg Traurig is also known for its philanthropic giving, culture, innovation, and pro bono work. Web: www.gtlaw.com.

Copyright © 2025, Greenberg Traurig, LLP. All Rights Reserved.
Law blog design & platform by LexBlog LexBlog Logo