While the U.S. Department of Justice has long-touted the high premium it places on self-disclosure in Foreign Corrupt Practices Act cases, defense counsel have long doubted the purported benefits. The DOJ has given defense counsel another reason to doubt.

On Sept. 9, the DOJ announced policy directives prioritizing individual prosecutions. U.S. Deputy Attorney General Sally Quillian Yates issued a memorandum detailing a six-step plan to strengthen the DOJ’s pursuit of individual corporate wrongdoers, both civilly and criminally. The Yates Memo reflects an aggressive stance by the DOJ regarding white-collar crime in corporate America and one that may tip the scales against self-disclosure in most FCPA cases.

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