DOJ Executes Its Return to Strict Corporate Compliance
The Justice Department is making critical policy changes for white-collar enforcement, including reinstating the so-called "Yates Memo" from 2015.
November 18, 2021 at 03:00 PM
7 minute read
Federal Government
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|The Shift: DOJ Executes Its Return to Strict Corporate Compliance
The Justice Department is making critical policy changes for white-collar enforcement, including reinstating the so-called "Yates Memo" from 2015. These newly instituted policies require companies seeking cooperation credit to divulge all relevant facts about individuals involved in any misconduct, and the Justice Department is taking a holistic approach when looking at companies' prior misconduct when deciding on potential charges or dispositions.
The white-collar bar is waiting to see how these policies are applied on the ground, with some lawyers saying the initiatives could make it more likely that companies will dig in and fight allegations if they see little incentive for cooperating.
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