In case there was any doubt, the U.S. Department of Justice is requiring companies to detail “individual accountability” if they expect any credit for cooperating with investigators in civil cases as well as criminal ones.
And this week it issued new guidance on what it expects from defendants in civil cases. William Baer, principal deputy associate attorney general, delineated the guidelines in a speech Wednesday to in-house counsel and compliance officers attending the Society of Corporate Compliance and Ethics Conference in Chicago. “This guidance makes clear that the department encourages productive self-disclosure and cooperation,” Baer says.
