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By Frank E. Sheeder The US Department of Justice has made it a priority to hold individuals accountable for organizational misdeeds – both civil and criminal. Through the recent Yates Memo, the DOJ is sending a message of deterrence to corporate leaders and their governing bodies. The Memo details a concerted DOJ initiative to hold individuals responsible for corporate misconduct. With this new initiative, the outcome of a government enforcement action against a corporation could hinge on its ability – and willingness – to turn in its leaders and other personnel. The DOJ’s focus on individuals will complicate internal investigations, defensive strategies, and resolution efforts. Moreover, prudent organizations will respond to the Yates Memo by assessing and enhancing their compliance programs to avoid becoming embroiled in government investigations in the first place. Find out more details in Frank’s recent article on this important topic.
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