Calling it a “big step forward” for the DOJ, Deputy Attorney General Sally Quillian Yates announced changes to the U.S. Attorneys’ Manual (USAM) on November 16, 2015 at the American Banking Association and American Bar Association Money Laundering Enforcement Conference in Washington, D.C. “We don’t revise the USAM that often and, when we do, it’s for something important.” The revised sections formalize the September 2015 Yates Memo by emphasizing the “primacy in any corporate case of holding individual wrongdoers accountable” including a change in cooperation credit. See “How Will the Yates Memo Change DOJ Enforcement? (Part One of Two),” The FCPA Report, Vol. 4, No. 19 (Sep. 23, 2015); Part Two, Vol. 4, No. 20 (Oct. 7, 2015).