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ARTICLE · 12 DECEMBER 2018

Red Notice Newsletter - November 2018

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Deputy Attorney General Rod Rosenstein Announces Pursuing Individuals Will be a "Top Priority" for Corporate Enforcement Actions.

GlobalInternational Law
Akin Gump Strauss Hauer & Feld LLP
Akin Gump Strauss Hauer & Feld LLP
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Deputy Attorney General Rod Rosenstein Announces Pursuing Individuals Will be a "Top Priority" for Corporate Enforcement Actions

On November 29, 2018, Deputy Attorney General Rod J. Rosenstein announced further revisions to the Department of Justice (DOJ) Justice Manual (f/k/a the United States Attorneys' Manual) concerning the DOJ's focus on the prosecution of individual wrongdoers in the investigation of corporate conduct. In a speech delivered to the 35th International Conference on the Foreign Corrupt Practices Act in Washington, D.C., Rosenstein remarked that "[u]nder [the] revised policy, pursuing individuals responsible for wrongdoing will be a top priority in every corporate investigation." Pursuant to this directive, Rosenstein remarked that the Justice Manual had been revised to make clear that: (i) "absent extraordinary circumstances, a corporate resolution should not protect individuals from criminal liability"; (ii) "any company seeking

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