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Caldwell Clarifies Application of the Yates Memo

Jaclyn Jaeger | September 23, 2015

During remarks at the Global Investigations Review conference, Leslie Caldwell, assistant attorney general for the Justice Department’s Criminal Division, offered some additional insight to companies on the Yates Memo regarding individual accountability for corporate wrongdoing.

As Compliance Week previously reported, the crux of the Justice Department’s new policy memo issued on Sept. 9 is this: “If a company wants any consideration for its cooperation, it must give up the individuals, no matter where they sit within the company.” Furthermore, to qualify for any cooperation credit, corporations must provide “all relevant facts” relating to the individuals responsible for the misconduct....

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