US DOJ Emphasizes Individual Accountability and Amends Approach to Cooperation Credit

The US Justice Department has adjusted its approach to holding individuals, and not only corporations, responsible for improper conduct. In remarks at the ACI’s FCPA conference on November 29, Deputy Attorney General Rod Rosenstein softened the DOJ’s formal policy on what information corporations are required to provide on individuals in order to receive credit in FCPA cases.

Rosenstein has effectively amended the Yates Memo, issued by Deputy Attorney General Sally Yates in 2015, which required companies to provide the DOJ with all relevant facts regarding individuals involved in corporate misconduct. This change follows Rosenstein’s announcement in September 2017 that the Yates Memo was under review within the DOJ.

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