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Understanding the ‘revised’ policy on cooperation credit

Jaclyn Jaeger | December 5, 2018

On Nov. 29, Deputy Attorney General Rod Rosenstein, in remarks at the American Conference Institute’s 35th International Conference on the Foreign Corrupt Practices Act, unveiled what he referred to as “revised policy” governing corporate investigations in both criminal and civil cases. These changes have been incorporated into the Justice Manual (formerly known as the U.S. Attorneys’ Manual) under its “Value of Cooperation” principle, Section 9-28.700.

Regarding criminal cases, the revised policy relaxes requirements memorialized in the 2015 “Yates Memorandum,” which required companies to disclose “all” relevant facts about the individuals involved to be eligible for “any” cooperation credit. Such an “all or nothing” policy...

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