DOJ Targets Individual Wrongdoers In New Guidelines

In a rather dramatic turn, the United States Department of Justice ("DOJ") recently released a new memorandum outlining policies instructing prosecutors to focus their efforts to secure evidence against individuals, as opposed to their corporate employers responsible for corporate wrongdoing. The memo comes in the face of criticism from a number of quarters that focusing enforcement against large corporations with deep pockets does little in terms of general deterrence in the marketplace, sending a clear signal that in conducting corporate investigations the DOJ is willing to pursue charges against both individual and corporate defendants, and emphasizing to leaders and corporate decision makers that wrongdoers will held accountable.