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 VSD Policy follows guiding principles issued by the Department, particularly the September 2022 memorandum by Deputy Attorney General Lisa Monaco (Monaco Memo) and more recently the DOJ's Criminal Division Corporate Enforcement and Voluntary Self-Disclosure Policy.
As ECS continues to stress the importance of robust environmental compliance programs and a sustained culture of compliance, it is important for companies, executives, boards, and investors to understand DOJ's expectations and, in turn, how meeting these expectations can protect the company's continued success. In a recent podcast, Todd S. Kim, the Assistant Attorney General (AAG) for ENRD, emphasized the Department's expectations for companies to develop and maintain a culture of ethical environmental compliance.
As the Biden administration and capital markets ramp up pressure on climate change, environmental, social, and corporate governance, and environmental compliance, DOJ's ECS recently released policy informs how companies build, maintain, and communicate strong environmental compliance programs.
Copyright 2023 Bloomberg Industry Group, Inc. (800-372-1033) Reproduced with permission. DOJ Expectations for Corporate Environmental Compliance Programs.
