The Future of Internal Investigations After the Yates Memorandum

On Sept. 9, 2015, Deputy Attorney General Sally Quillian Yates became the fifth deputy attorney general in 15 years to issue a memorandum addressing prosecution of corporate wrongdoing. Deputy Attorney General Yates’ Memorandum, entitled "Individual Accountability for Corporate Wrongdoing" (Yates Memorandum), was another step in the effort by the Department of Justice to encourage the prosecution of individual corporate wrongdoers, and to encourage corporations to produce information to the government that would help fuel those prosecutions. Among other things, the memo prohibits providing any mitigation to a wrongdoing company if that company "declines . . . to provide the Department with complete factual information."

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