The Yates Memo is alive and well. Even if the Justice Department revises and clarifies the Yates Memo, the substance of what Sally Yates was communicating is alive and kicking. That is, if individuals violate the law, they will be prosecuted by the Justice Department. Over the past 10 days or so, the Justice Department unveiled a total of seven charging documents for FCPA violations, five arising from the Rolls Royce enforcement action and two from an upcoming enforcement action against SBM Offshore. Six of those individuals have pled guilty and one is fugitive from justice.
