Earlier this year, Deputy Attorney General Sally Quillian Yates issued new guidance outlining the DOJ's increased focus on individual accountability during civil and criminal investigations of corporate wrongdoing. The principles announced in the "Yates Memo" serve as the basis for revisions to the U.S. Attorney's Manual – particularly the section outlining the Principles of Federal Prosecution of Business Organizations – released November 16, 2015. While many of the principles outlined in the Yates Memo and recent revisions to the U.S. Attorney's Manual are consistent with DOJ's prior practice and rhetoric regarding white collar investigations, the emphasis on individual accountability requires companies to consider carefully those aspects of an internal investigation with consequences on individual executives and employees.
The Yates Memo outlines six "key step" to guide the Department’s investigations of corporate misconduct as it strengthens its focus on individual accountability for corporate wrongdoing.
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