Since the recent publication of the so-called Yates memorandum [1] setting out the Department of Justice’s (DOJ) strategy of targeting individuals for prosecution, we’ve seen several recent cases where the Government has not secured a conviction.[2] For some companies, this has strengthened their resolve to resist instituting a compliance program. However, I can relate from personal experience working at a company under Government indictment that the DOJ doesn’t need to…
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