Yates Sees Compliance Officers As DOJ's 'Crucial Partner'

Law360, New York (November 17, 2015, 7:33 PM EST) -- On Monday, Sally Q. Yates, the deputy attorney general in the U.S. Department of Justice, spoke before a group of bankers, lawyers and compliance officials in Washington, D.C., about the new DOJ corporate enforcement strategy she announced in a publicly distributed memorandum on Sept. 9, 2015.[1] Also Monday, this strategy was incorporated in the "Principles of Federal Prosecution of Business Organizations" (found in the U.S. Attorney's Manual), emphasizing the importance of holding individual wrongdoers accountable in cases where a corporation may be criminally liable. She identified six steps, including internal reporting and approval requirements, to accomplish this. The incorporation of the Yates memorandum into the USAM was done to ensure consistency among all assistant U.S. attorneys in the 93 field offices and at Main Justice. Yates described the USAM as "one of the most important documents within the Justice Department community."...

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