Having a compliance program in place is a start but having an effective compliance program is the goal. Proactively assessing the effectiveness of one’s own compliance program is better than…
Beware of Individual Liability: Yates Memo
On September 9, 2015, the Department of Justice (DOJ) Deputy Attorney General Sally Yates released a policy memorandum, titled “Individual Accountability for Corporate Wrongdoing,” also known as the “Yates Memo.”…