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PepsiCo Re-Hires Larry Thompson as GC

Scuttlebutt | June 19, 2012

Larry Thompson, the former deputy attorney general under the Bush Administration who helped usher in the Justice Department's modern approach to handling corporate fraud, has rejoined PepsiCo as general counsel—a position he had held at the company from 2004 to 2011, and vacated less than one year ago.

Pepsi's current general counsel, Maura Abeln Smith, has resigned to pursue other unspecified opportunities.

As general counsel, Thompson will also oversee the $65 billion food giant's compliance and government affairs functions, as well as its philanthropic arm.

During his one-year absence, Thompson had been teaching law at the University of Georgia. His name also routinely crops up in Republican circles as a possible attorney general or Supreme Court appointee.

Among compliance professionals Thompson is most well-known for authoring “the Thompson Memo” in 2003, which outlined how the Justice Department would approach the prosecution of business organizations. Thompson was deputy attorney general and head of the Justice Department's Corporate Fraud Task Force at the time, and prosecutions against Arthur Andersen, Enron, WorldCom, and other corporate offenders still dominated headlines.

His memo spelled out the department's criteria for deciding whether corporations should be charged, and its words were studied like the entrails of sacrificial birds in the Dark Ages. Thompson's criteria for a corporation to avoid charges of criminal misconduct—a nightmare scenario for a public company—were fierce: the company had to waive attorney-client privilege, surrender any useful evidence found during an internal investigation, and not provide targeted executives with company-paid legal representation.

After Thompson's exit from the Justice Department, subsequent deputy attorney generals issued their own memos (the McNulty Memo, followed by the Morford Memo, and so on), each slightly relaxing the stern criteria set forth by Thompson. That practice finally came to an end at the end of the Bush Administration.