Move over Holder, Thompson, McNulty, and Filip and make room for Yates. Taking its place in the parade of guidelines issued by top Department of Justice leadership on the topic of prosecuting business organizations comes a new entry from Deputy Attorney General Sally Quillian Yates. On Sept. 9, 2015, Yates issued a memorandum titled “Individual Accountability for Corporate Wrongdoing” (the Yates Memorandum), setting forth six steps to be taken in the investigation of corporate misconduct in order to “fully leverage [the department's] resources to identify culpable individuals…in corporate cases.”1 With a degree of fanfare, the new regime at the Justice Department has announced that it intends to target individual employees for corporate wrongdoing rather than simply the companies that employ them.
To those who practice in this area, that goal is nothing new. Indeed, experience has shown that the guidance memoranda issued by Justice Department leaders have varying import—some contain specific policy directives that mark a shift in the way the department does business, while others serve more as a public relations tool to inform observers about the department’s attitudes and priorities.
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