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Over the past year, building off the 2015 Yates Memorandum, which had emphasized that holding individuals accountable for corporate misconduct has an important deterrent effect and incentivizes appropriate change in the way businesses behave, the Fraud Section of the U.S. Department of Justice (DOJ) has significantly increased individual prosecutions. The Fraud Section charged more individuals in 2018 than in previous years. The Foreign Corrupt Practices Act (FCPA) unit in particular emphasized its “clear commitment to holding individuals accountable for transnational corruption.” (DAAG, Matthew S. Miner, Remarks at 5th Annual GIR New York Live Event, Sept. 27, 2018).

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