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Internal Investigations Personal Liability

Harris Beach PLLC

DOJ Issues Guidelines for Cooperation Credit Specifically as to False Claims Act Matters

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The United States Department of Justice (DOJ) has issued new guidelines regarding cooperation and credit for self-disclosure specifically in False Claims Act matters. Such guidelines provide an overview of factors to be...more

Skadden, Arps, Slate, Meagher & Flom LLP

Skadden's 2019 Insights: Expanding Theories of Liability in the #MeToo Era

Alleged workplace harassment is not a new phenomenon, but in the wake of allegations of sexual misconduct in the corporate context, plaintiffs increasingly are targeting an expanded group of defendants, including public...more

NAVEX

Top 10 Ethics & Compliance Predictions and Recommendations for 2017

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Once again it’s time for our annual review of trends and events that will impact your Ethics and Compliance (E&C) program in the year ahead. This year presents a unique challenge. We are preparing our predictions...more

Parker Poe Adams & Bernstein LLP

New DOJ Corporate Prosecution Guidelines

On September 9, 2015, United States Deputy Attorney General Sally Yates released a memorandum titled “Individual Accountability for Corporate Wrongdoing,” the latest in a series of corporate prosecution guidelines written by...more

Morrison & Foerster LLP

Pay Attention to the Man Behind the Curtain: DOJ Memorandum Adds Further Weight to CPSC Enforcement Efforts Against Corporate...

The United States Department of Justice (DOJ) recently issued a memorandum to various enforcement agencies. The memorandum, available here, focuses on holding individuals accountable for corporate fraud and misconduct. The...more

Mintz - Health Care Viewpoints

DOJ Clarifies Position on Individual Accountability in Corporate Investigations

Earlier this month, we discussed a memorandum issued by Deputy Attorney General Sally Quillian Yates of the U.S. Department of Justice (DOJ). This memorandum, referred to as the “Yates Memo,” reaffirms the Government’s...more

Akerman LLP

DOJ's New Guidance Directing Prosecutors to Target Individuals Responsible for Corporate Wrongdoing Calls for Clarification

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On September 9, 2015, the Department of Justice ("DOJ") issued written guidance by the Deputy Attorney General Sally Quillen Yates on investigating and prosecuting individuals involved in alleged corporate wrongdoing (the...more

NAVEX

Despite Criticism, DOJ’s New Policy On Internal Investigations Could Be a Good Thing

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While naysayers believe the Department Of Justice's (DOJ’s) memo is going to result in major complications and headaches for companies experiencing government investigations, ethical companies are unlikely to be affected much...more

Mintz - Securities & Capital Markets...

Assistant Attorney General Caldwell Clarifies Application of Yates Memo on Individual Accountability

On September 22, 2015, the U.S. Department of Justice’s Assistant Attorney General in charge of the Criminal Division, Leslie R. Caldwell, spoke at the Global Investigations Review Conference in New York, addressing the...more

Manatt, Phelps & Phillips, LLP

New DOJ Policy Alert: Here's Looking at You, Kid - DOJ Announces Six Specific Steps to Hold Individual "Corporate Wrongdoers"...

Why it matters: On September 9, 2015, Deputy Attorney General Sally Quillian Yates issued a memo to all DOJ department heads and U.S. Attorneys which detailed the Government's new policy centered on accountability for the...more

Foley & Lardner LLP

DOJ Provides Guidance on Prosecution of Individuals

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The Department of Justice (DOJ) long has required entities seeking credit for cooperating with its investigations to provide what it terms “full and truthful” cooperation. In policies memorialized over time, DOJ has been...more

Morrison & Foerster LLP

Three Key Takeaways from DOJ’s New Yates Memo on Individual Accountability for Corporate Wrongdoing

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...more

Womble Bond Dickinson

DOJ Provides Focused “Guidance” on Prosecuting Corporate Individuals

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After receiving significant criticism on the Department of Justice’s failure to prosecute corporate executives involved in the financial crisis in 2008, Sally Yates, the Deputy Attorney General issued a seven page memo...more

Morgan Lewis

US Department Of Justice Targets Corporate Individuals

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DOJ announces tough new approach to the investigation and prosecution of corporate officers and employees. On September 9, in a major change to its approach to the investigation of alleged corporate crime, the US...more

McGuireWoods LLP

Unpacking the Yates Memo: What the "New" DOJ Policy Really Means

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The DOJ made a significant splash on Wednesday when a memorandum from Deputy Attorney General Sally Quillian Yates to all DOJ attorneys, including the U.S. Attorneys across the country, announced a policy to increasingly...more

Beveridge & Diamond PC

Executives Beware: DOJ’s New Policy Memo Signals Focus on Prosecuting Individuals

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In light of the near-unbridled discretion of the U.S. Department of Justice (“DOJ”) to bring federal criminal charges, businesses and their leaders are wise to pay close attention to the prosecutor’s “playbook.” Sometimes...more

Alston & Bird

“Individual Accountability for Corporate Wrongdoing”: The Yates Memo and the DOJ’s Focus on Individuals

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On September 9, 2015, the Department of Justice issued a memo (“Individual Accountability for Corporate Wrongdoing”) to federal prosecutors nationwide implementing new policies that—for the first time—prioritize the...more

Thomas Fox - Compliance Evangelist

FCPA Compliance and Ethics Report-Episode 122-with Matt Kelly on Alstom, Avon and Petrobras

In this episode, Compliance Week Editor-in-Chief Matt Kelly and I discuss the Avon and Alstom FCPA enforcement actions and then take a look at the ongoing Petrobras corruption scandal and what it means for Brazil. ...more

Stinson LLP

SEC Charges Audit Committee Chair for Failing to Investigate Red Flags

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The SEC recently brought an enforcement action against the Chairman of the Audit Committee of AgFeed Industries, Inc. The Director of the SEC’s Division of Enforcement, called the AgFeed action “a cautionary tale of what...more

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