As practitioners who represent corporations and individuals in Department of Justice investigations, we reliably anticipate that each new administration will revamp the policies and procedures for corporate prosecutions inherited from its predecessors. The task of articulating new policy has traditionally fallen to the Deputy Attorney General, and the files are filled with memoranda that officially or unofficially bear their names. True to form, Deputy Attorney General Rod Rosenstein, speaking at the NYU Program on Corporate Compliance & Enforcement on Oct. 6, 2017, expressed his desire to reconsider both the form and substance of the Department’s past guidance. He criticized the Department’s practice of releasing guidance through successive speeches and memoranda, protested that such pronouncements are commonly referred to by the author’s name, and proposed consolidating DOJ policy through regular updates to the U.S. Attorneys’ Manual. As part of this effort, Rosenstein unsurprisingly announced that the Department would review former Deputy Attorney General Sally Yates’ September 2015 memorandum on individual accountability for corporate wrongdoing, known of course as the “Yates Memo.”
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