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The Shift: DOJ Executes Its Return to Strict Corporate Compliance
The Justice Department is making critical policy changes for white-collar enforcement, including reinstating the so-called “Yates Memo” from 2015. These newly instituted policies require companies seeking cooperation credit to divulge all relevant facts about individuals involved in any misconduct, and the Justice Department is taking a holistic approach when looking at companies’ prior misconduct when deciding on potential charges or dispositions.