Department of Justice eases “Yates Memo” requirements for cooperation credit
Dec 02, 2018
On December 2, 2018, the D&O Diary published an article on how one of the important questions about U.S. Department of Justice’s approach following the change of Presidential Administration two years ago was whether DOJ would continue emphasizing its policy of individual accountability in the agency’s 2015 statement known as the Yates Memo.
In a recent speech, Deputy Attorney General Rod J. Rosenstein announced changes to the policy. The changes, which are more in the form of an adjustment rather than a wholesale change, makes it clear that companies seeking cooperation credit no longer need to identify “all” individuals involved in the wrongdoing, so long as the companies identify those who were “substantially involved” in the misconduct.
Review the full article on the D&O Diary's website.