Prompt Self-Reporting of Regulatory Violations Leads to Significantly Reduced Civil Penalties Under EPA’s Audit Policy

Victor N. Baltera, Laura Ford Brust, Jeffrey M. Karp, Jerome C. Muys Jr., Julie A. Weisman
May 14, 2007

This Advisory discusses how companies that fulfill the requirements of EPA's Audit Policy, including the systematic discovery and self-reporting of regulatory violations, can significantly ameliorate civil penalties imposed for such violations. Kmart recently avoided $1.5 million in civil penalties by meeting the conditions of EPA's Audit Policy.

Client Advisory (PDF)