Global Investigations Review - The law and practice of international investigations

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Yates memo change turns attention to meaning of substantial involvement

By Adam Dobrik

30 November 2018

Yates memo change turns attention to meaning of substantial involvement The Gaylord, National Harbor, Maryland – where the FCPA conference is held. Craig Pennington on Flickr (CC BY 2.0)

The DOJ’s changes to a three-year-old policy on prosecuting individuals in corporate cases raises questions, but government officials don’t quite have all the answers yet.