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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.

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Photo of Steven C. Russo Steven C. Russo

Steven C. Russo chairs the firm’s New York Environmental Practice. He focuses his practice on environmental law and litigation, environmental permitting, National Environmental Policy Act (NEPA), State Environmental Quality Review Act (SEQRA) review, toxic tort litigation, environmental crimes, Brownfields redevelopment, government, energy and

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Steven C. Russo chairs the firm’s New York Environmental Practice. He focuses his practice on environmental law and litigation, environmental permitting, National Environmental Policy Act (NEPA), State Environmental Quality Review Act (SEQRA) review, toxic tort litigation, environmental crimes, Brownfields redevelopment, government, energy and the environmental aspects 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 environmental liability risk and due diligence, permitting, Brownfields, and impact assessment and review. 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 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.

Steven also serves as election law counsel to a number of New York State and federal campaigns and political parties.

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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.

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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

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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.

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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

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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.

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