What’s The Impact Of The Yates Memo In The Real World?
September 24, 2015 by David Rudolf
Heralded in a DOJ press release as the key to increased prosecutions of high-level corporate executives who have otherwise allegedly “insulated” themselves from criminal responsibility for corporate acts (presumably because they are, by definition, not involved in or even aware of criminal conduct by lower level employees), at least one aspect of the new DOJ policy on corporate “cooperation” has real-life consequences for how corporations respond to federal investigations in the future. The Yates Memo, promulgated by DOJ on September 9, 2015, provides in paragraph 1 of its “six key steps” that “to be eligible for any credit for cooperation, […] More...