Six Guidelines For Understanding The Yates Memo

Much ink already has been spilt on the September 9, 2015 Department of Justice policy memorandum signed by Deputy Attorney General Sally Yates. The Yates Memo signaled a shift in the DOJ's approach to prosecution of white-collar crime towards an increased focus on pursuing individual executives and employees for corporate wrongs. 

To this end, the Yates Memo set forth six guiding principles for DOJ attorneys to follow. 

1. To be eligible for any cooperation credit, corporations must provide to the DOJ all relevant facts about the individuals involved in the corporate misconduct. 
2. Both criminal and civil DOJ corporate investigations should focus on individuals from the inception of the investigation.