The Yates Memo – and what you can do about it
A policy statement issued last September by Deputy Attorney General Sally Quillian Yates is seen by some as heralding a new era of individual accountability in corporate investigations, although there are plenty of skeptics too about the prospect for genuine change in this regard. (My own position can be described as cynical but forever optimistic.)
But even the most hardened cynic would agree that there is some chance that things will now be different when it comes to individual accountability for corporate wrongdoing, and so it is fair to ask: Does your company have a policy on this policy?
In my latest column in Compliance & Ethics Professional I offer two suggestions on how C&E officers can respond to this potentially significant development.