During a September 10, 2015 conference at New York University, Deputy Attorney General (DAG) Sally Quillian Yates announced new Department of Justice (DOJ or the Department) policy that could significantly affect the way that companies cooperate with DOJ in criminal and civil investigations. DAG Yates expressly acknowledged the difficulties of bringing cases against individuals for corporate misdeeds and implicitly addressed the chorus of critics who have faulted DOJ for what they view as a failure to hold individuals accountable for the 2008 financial crisis and other recent corporate scandals. Yates then revealed that she had issued a new policy memo regarding “Individual Accountability for Corporate Wrongdoing” (the Yates Memo), the provisions of which will eventually be incorporated into two parts of the U.S. Attorney’s Manual (USAM) that govern criminal and civil corporate investigations—the Principles of Federal Prosecution of Business Organizations and the USAM’s civil litigation provisions.