Justice Dept. Mulling Yates Memo Policy Clarifications


Michael Peregrine suggested there will likely be a nuanced shift to guideposts laid out in the Yates memo on individual prosecution for corporate misconduct, rather than a direct or complete repeal or revision. Mr. Peregrine warned corporate boards that “executives will misperceive the message” of any modification and relax on compliance spending and diligence, and urged boards to maintain robust compliance programs.