How Will the Yates Memo Change DOJ Enforcement? (Part One of Two)

Under pressure to hold individuals accountable, the DOJ says it will be intensifying its focus on individuals by taking six key steps during investigations.  Deputy Attorney General Sally Quillian Yates issued a memo to all U.S. Attorneys outlining the steps she says will strengthen the DOJ’s pursuit of corporate wrongdoing.  Former DOJ attorneys talked to The FCPA Report about the implications of what the DOJ is characterizing as a policy shift.  The first article in this two-part series discusses the extent to which the memo may change the enforcement climate and the cooperation calculus for companies and individuals.  The second part addresses how focusing on individuals earlier in the investigations and the increased coordination of efforts between the DOJ’s civil and criminal divisions may affect internal investigations.  See “Top DOJ and SEC Officials Discuss FCPA Enforcement Priorities and Mechanics,” The FCPA Report, Vol. 3, No. 7 (Apr. 2, 2014).

To read the full article

Continue reading your article with an ACR subscription.