Former Prosecutor Nat Edmonds Discusses the Implications of the Recent Changes to the U.S. Attorneys’ Manual (Part One of Two)

In November 2015, Deputy Attorney General Sally Quillian Yates announced that the section of the U.S. Attorneys’ Manual (USAM) codifying the principles governing the prosecution of business organizations had been updated to reflect the DOJ’s efforts to hold more individuals accountable for corporate criminal activity. Yates said the changes, which are publicly available, will give companies insight into how the government’s policy will be applied during the “everyday work” of federal prosecutors. Former prosecutor Nat Edmonds, now a partner at Paul Hastings, told the Anti-Corruption Report that the changes don’t indicate an actual “policy shift,” but rather a “formalization” of DOJ best practices. Yet, he emphasized, the subtle shifts in the USAM language may require a change in strategy when a company is faced with an FCPA investigation. We share his insight in a two-part series. See also “How Will the Yates Memo Change DOJ Enforcement? (Part One of Two)” (Sep. 23, 2015); Part Two (Oct. 7, 2015).

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