Enforcement & Litigation Support

Enforcement Teams

We work on cases that are:

• Referred by ONRR employees and external parties for enforceability.
• Based on violations that are likely to have occurred and are not beyond the statute of limitations.
• Remanded or referred by OIG.
• Not for potential criminal or false claims. We refer those to the Office of Inspector General (OIG) Energy Investigations Unit.

When we work on a case we:

• Identify parties responsible for violations and profile them for the record.
• Locate violators who we cannot contact through ONRR database information.
• Determine why violations occurred.
• Determine whether the violator knowlingly and willfully committed the violations, when relevant.
• Marshal evidence to support enforcement cases against the violators.
• Issue appropriate enforcement actions, including civil penalties.
• Follow up with case referrers and subject matter experts on the result of the case.

We also:

• Testify in administrative hearings on civil penalty assessments.
• Train ONRR employees to recognize and properly refer violations.

Civil Penalties

The two enforcement teams administer our civil penalty program to encourage compliance and deter future compliance violations.

We issue civil penalties when companies fail to follow applicable regulations or laws. Such penalties are authorized by the Federal Oil and Gas Royalty Management Act of 1982 (FOGRMA). ONRR has collected more than $60 million in civil penalties since its start in 1982.

ONRR regulations at 30 CFR 1241 provide a grace period of at least 20 days for regulatory violations, such as failure to submit reports. Violations not fixed within the grace period are subject to civil penalties until fixed. These penalties can be up to $1,562.00 per day ($15,628.00 per day after 40 days), based on the January 2025 update to 30 CFR 1241.52.

Certain violations, such as failure to permit an audit, failure to timely pay royalties, or submission/maintenance of false, inaccurate, or misleading information are subject to higher civil penalties. They can be as much as $31,252.00 or $78,134.00 per violation for each day the violation continues, based on the January 2025 update to 30 CFR 1241.60.

Some violations are also crimes under Title 18, U.S.C. or False Claims under 31 U.S.C. 3729. ONRR works in partnership with the Department’s Office of the Inspector General and the U.S. Attorney’s Office in pursuing these violations.

Bankruptcies & Litigation Support

When companies with mineral revenue lease obligations file for bankruptcy, the Litigation Support Team:

• Ensures companies consider the government's interests when selling or assuming leases.
• Reviews the debtor's Disclosure Statement and Plan of Reorganization. 
• Provides the Solicitor's Office with the Proof of Claim for filing with the bankruptcy court. 
• Coordinates with other federal agencies to resolve the bankruptcy. We work with the Solicitor's Office, Department of Justice, Bureau of Ocean Energy Management, Bureau of Safety and Environmental Enforcement, Bureau of Land Management, Bureau of Indian Affairs, and other federal agencies.

Whether litigation is in the bankruptcy context or not, the Litigation Support Team:

• Acts as a liaison between ONRR, the Solicitor’s Office, and the Department of Justice (DOJ).Gathers and provides the administrative record to the Solicitor's Office when ONRR decisions are appealed to the Interior Board of Land Appeals.
• Coordinates and prepares litigation cases throughout the evidentiary and hearing process.
• Reviews the financial solvency of civil penalty litigants when litigants seek a compromise based on their insolvency.

Contacts