Employee Discipline and Internal Investigations After the Yates Memo

Over the past year, the Department of Justice has reiterated and re-emphasized its focus on holding individuals accountable for corporate wrongdoing. For companies investigating potential FCPA violations, these mandates raise the stakes on the already complex issue of employee discipline. In a guest article, Paul Hastings partner Palmina M. Fava and her associate Mor Wetzler explain how companies must balance the need to promptly remediate and discipline wrongdoing with not depriving the company of access to employees before obtaining all of the facts needed to fully understand the issues. See “How Will the Yates Memo Change DOJ Enforcement? (Part One of Two)” (Sep. 23, 2015); Part Two (Oct. 7, 2015).

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