DOJ Increases Focus On Individual Accountability In Corporate Wrongdoing

US Deputy Attorney General Rod J. Rosenstein recently announced that in every corporate investigation, the US Department of Justice will make it a top priority to pursue individuals responsible for corporate wrongdoing. This revised policy also modifies the expectations for corporate targets seeking cooperation credit in criminal and civil investigations. Cooperation credit for corporate targets of criminal investigations remains "all or nothing," while cooperation credit will be available in degrees for corporate targets in civil investigations.

At the American Conference Institute's 35th International Conference on the Foreign Corrupt Practices Act on November 29, US Deputy Attorney General Rod J. Rosenstein declared a revised policy concerning individual accountability in every corporate investigation—one that places "pursuing individuals responsible for wrongdoing" as a "top priority."