Posts Tagged ‘yates memo’

Rosenstein Talks Yates Memo, Says Diddly

fcpa

Don’t look now, but the compliance Internet is all a-Twitter today because Deputy Attorney General Rod Rosenstein said in a public forum that maybe, sometime soon, the Justice Department might change its views of corporate cooperation under the Yates Memo— or then again, maybe not. Who knows, really. To remind everyone, the Yates Memo is…

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The Other FCPA Investigation Worth Following

fcpa

Washington gave the compliance community a bucket of FCPA enforcement actions to study last week, from the Ochs-Ziff settlement (holding a chief executive personally liable for misconduct) to the HMT and NCH Corp. deals (declining to file charges, but taking ill-gotten gains back from the companies anyway). To my mind, however, the most interesting FCPA…

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More on Internal Investigations, Yates Memo

Last week we looked at a recent federal appeals court ruling, Gilman v. Marsh McLennan, that affirms a considerable amount of power for compliance and legal officers conducting internal investigations. The decision has enough potential implications to warrant a follow-up post, so let’s keep going. I won’t rehash my earlier post here. Suffice to say…

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U.S. Chamber Aims Fire at Yates Memo

bench

The U.S. Chamber of Commerce published a lengthy critique of the Yates Memo yesterday, and cynics who believe the memo is a powerful threat to internal investigations will be pleased. Others who don’t believe the memo is a threat should be more cynical. Obviously the Chamber has an agenda with this paper, like it has…

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Dueling Perspectives on Compliance & Yates Memo

bench

There we were—me, the Lawyer from a large law firm in the United States, and the Ethics Consultant who works with large companies here and in Europe. We were talking about the Yates Memo, and its possible consequences for companies under investigation by the Justice Department. First, a refresher for anyone unfamiliar with the Yates…

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