DOJ Further Revises Corporate Criminal Enforcement Policies: Focusing on Individual Accountability, Corporate Responsibility, and Additional Demands on Chief Compliance Officers
Health Law Advisor
OCTOBER 5, 2022
To that end, the new policies build upon the 2015 Yates Memo , requiring corporations to disclose “all relevant, non-privileged facts and evidence about individual misconduct” in a timely fashion, particularly if corporations want to receive cooperation credit. This may have a chilling effect on companies seeking to retain qualified CCOs.
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