Department of Justice Announces Revision of Yates Memo

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In September 2015, then-Deputy Attorney General Sally Yates announced revised Department of Justice (DOJ) standards relating to individual accountability for corporate wrongdoing. Under the “Yates Memo,” in “order for a company to receive any consideration for cooperation under the Principles of Federal Prosecution of Business Organizations, the company must completely disclose to the Department all relevant facts about individual misconduct.” Consistent with this requirement, policy required that a company “must identify all individuals involved in or for the misconduct” as a prerequisite to receiving any credit.