Global Investigations Review Quotes John Adams on Yates Memo Tweaks

January 10, 2019

For an article in its Jan. 9 issue, Global Investigations Review sought out Richmond partner John Adams for his insights on recent changes to the so-called Yates Memo outlining Justice Department policy for investigations into corporate wrongdoing.

Deputy Attorney General Rod Rosenstein announced in a Nov. 30 speech that parts of former Deputy Attorney General Sally Yates’ 2015 memorandum — officially titled “Individual Accountability for Corporate Wrongdoing” — were amended to grant more flexibility in both civil and criminal investigations.

Adams, a former assistant U.S. attorney, said he welcomes a change that affords companies cooperation credit for their good-faith efforts to identify all individuals substantially involved in or responsible for wrongdoing.

“This modification reflects the reality of criminal investigations: that we should focus time and resources only on the heart of the matter,” Adams said.

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