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Annual ISDC Reporting

Client Alert | less than 1 min read | 11.07.19

The annual Interagency Suspension and Debarment Committee recently issued its annual report to Congress. The report, found here, contains details of the state of the federal suspension and debarment program for Fiscal Year 2018 (note the significant timelag). The report notes a focus on cybersecurity contractor compliance issues, and proposals to modernize/streamline lead agency coordination. Otherwise, total numbers of suspensions, proposed debarments, and debarments continued to decline year-over-year, while pre-notice interactions with contractors continued to comprise a significant portion of SDO offices’ dockets.

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Client Alert | 3 min read | 04.25.24

JUST RELEASED: EPA’s Bold New Strategic Civil-Criminal Enforcement Collaboration Policy

The Environmental Protection Agency’s (EPA’s) Office of Enforcement and Compliance Assurance (OECA) just issued its new Strategic Civil-Criminal Enforcement Policy, setting the stage for the new manner in which the agency manages its pollution investigations. David M. Uhlmann, the head of OECA, signed the Policy memorandum on April 17, 2024, in order to ensure that EPA’s civil and criminal enforcement offices collaborate efficiently and consistently in cases across the nation. The Policy states, “EPA must exercise enforcement discretion reasonably when deciding whether a particular matter warrants criminal, civil, or administrative enforcement. Criminal enforcement should be reserved for the most egregious violations.” Uhlmann repeated this statement during a luncheon on April 23, 2024, while also emphasizing the new level of energy this collaborative effort has brought to the enforcement programs....