Environmental Auditing and Audit Disclosure in a New Era

CHANGING ENFORCEMENT EMPHASIS • History of “retail enforcement” • More recent outcomes-based enforcement targeting ‒ Likely no going back from the targeting of larger sources – priority • Changing enforcement tools: focus on required reporting, electronic paper trail, advanced technologies, information requests ‒ Trend toward “desktop enforcement” • Although new Administration seems more focused on rule of law than outcomes-based initiatives, “desktop” is likely to dominate ‒ Easier cases to make when it’s literally black and white ‒ Budget/FTE/Resource constraints

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