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ARTICLE · 04 NOVEMBER 2025

Self-Audits In Transactional Due Diligence And Enforcement Contexts – Prepare Your Company

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The second Trump administration has launched a broad deregulatory agenda at the US Environmental Protection Agency (USEPA), refocusing the Agency's mission and redirecting enforcement priorities and resources.

United StatesEnvironment
Michael Boucher
Michael Boucher
Nina MacLeay
Nina MacLeay

The second Trump administration has launched a broad deregulatory agenda at the US Environmental Protection Agency (USEPA), refocusing the Agency's mission and redirecting enforcement priorities and resources. The implications for enforcement against chemical manufacturers under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) and the Toxic Substances Control Act (TSCA)1remain uncertain. Now is the ideal time to leverage USEPA's Audit Policy self-disclosure provisions.

As the Trump administration reorganizes USEPA's Office of Enforcement and Compliance Assurance (OECA), adjusts the Agency's enforcement priorities, and reallocates enforcement resources at bothUSEPA and the US Department of Justice (USDOJ), companies should not reduce their compliance efforts. Instead, businesses should conduct internal audits, review product stewardship and environmental, health, and safety procedures, and ensure that all activities and products comply fully with

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