US - DOJ Softens Yates Memo Approach to Individual Liability in Corporate Cases

At an FCPA conference on 29 November 2018, Deputy Attorney General Rod Rosenstein announced a number of revisions to the DOJ's policies concerning individual accountability in corporate cases, and in particular softening the so-called Yates Memo's guidance on individual accountability in criminal prosecutions. The revised approach makes clear that any company seeking cooperation credit in criminal cases must identify every individual who was substantially involved in or responsible for the cri