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DOJ Announces Revisions to Policy on Corporate Cooperation

US Department of Justice, Wikimedia Commons

US Department of Justice, Wikimedia Commons

In a November 29, 2018 speech,1 Deputy Attorney General Rod Rosenstein announced a softening of the US Department of Justice’s (DOJ) policy on giving credit for cooperation in corporate prosecutions.

As memorialized in the 2015 memo titled Individual Accountability for Corporate Wrongdoing (known as the “Yates Memorandum”),2 DOJ had followed an “all or nothing” policy that barred corporate defendants from receiving cooperation credit if they failed to provide information on all employees who were involved in criminal conduct.

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