The Department of Justice has released a new policy intended to further the Department’s effort to hold individuals accountable for corporate wrongdoing. The policy was laid out in a September 9, 2015 memorandum authored by Deputy Attorney General Sally Quillian Yates. The new policy is more than a clarification of existing practices; it constitutes the most significant new measures taken since the Department intensified its focus on pursuing white collar cases against individuals last year. The policy, and in particular the requirement that corporations provide the Department with “all relevant facts relating to the individuals responsible for the misconduct” in order to receive any cooperation credit, could have significant implications for how corporations investigate potential misconduct and share factual findings with the Department.
‘Enforcement 40’ for 2020
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