The Yates Memo and the new normal for individual enforcement
In a speech before the New York bar, Justice Department Deputy Assistant Sally Yates detailed some of the effects the Justice Department has already seen from the Yates Memo, released last September, including a larger focus on individual actor culpability and a drive by DoJ lawyers to identify the individuals ...
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Navigating the risks of individual accountability for corporate wrongdoing
How can directors and officers better protect themselves and their organizations in a post-Yates Memo era of accountability? Kevin Hyams has some answers.
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PremiumBribery risk elevated, experts say, as DOJ narrows FCPA enforcement
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 ...
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PremiumAfter a six-month enforcement pause, DOJ will again pursue FPCA investigations
The Department of Justice has ended its six-month FCPA enforcement pause, closed half its legacy bribery cases, and will now pursue foreign bribery probes aligned with President Donald Trump’s priorities.