Yates on the Yates Memo

Depending on which client alert one reads from the defense bar, the DOJ’s new policy on pursuing individual wrongdoing has meant that the “sky is falling” or that nothing has changed at all, according to Deputy Attorney General Sally Q. Yates. In her remarks at the recent New York City Bar White Collar Crime Institute, she noted that “the truth, as it often is, is somewhere in the middle.” Conceding that before her eponymously titled memo, the DOJ sometimes gave companies cooperation credit even when companies didn’t identify any individuals, she described what has changed since the Yates Memo has taken effect. See “How Will the Yates Memo Change DOJ Enforcement?”: Part One (Sep. 23, 2015); Part Two (Oct. 7, 2015).

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