Potential VW criminal resolution—an early test for Yates Memo?
A look at potential VW criminal resolutions brings up several questions, says Tom Fox, around type of resolution; individual liability; and more. Will this test the DoJ’s Yates Memo?
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When the U.S. Department of Justice announced a six-month enforcement pause of the Foreign Corrupt Practices Act (FCPA) in February, many speculated that the risks posed by bribery had been lowered. So when the DOJ said last week that it would resume launching FCPA investigations, it may just seem like ...