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
Continue Reading DOJ’s Updated Corporate Crime Policies: Practical Considerations in the Environmental ContextOn July 27, 2020, the U.S. Department of Justice (DOJ) issued a policy memorandum designed to stay the federal government’s hand in enforcing the Clean Water Act where states have
Continue Reading New DOJ Guidance Seeks to Limit Federal Enforcement under the Clean Water Act
The Department of Justice, in the last year, has altered its guidance related to supplemental environmental projects (SEPs), first prohibiting their use in settlements with state and local governments,
Continue Reading DOJ’s Attack on ‘Supplemental Environmental Projects’ Extends to Citizen Plaintiffs