Yates Memorandum – Focus on Individual Wrongdoing to Promote Compliance

    View Author September 2016

    This month marks the one-year anniversary of the Yates Memorandum, the Department of Justice memorandum drafted by Deputy Attorney General Sally Quillian Yates, which announced revisions to the US Attorney’s Manual (USAM). One purpose of the Yates Memorandum was to refocus corporate compliance on individual accountability. To do so, it created incentives for company officers to prioritize a compliance culture in an arena where compliance was often viewed as an unnecessary bureaucratic burden and secondary to success as measured by profit. 

    This article, published in the September 9, 2016 issue of Securities Regulation Daily, examines how companies are meeting the lofty goal of creating a culture of compliance that is central to corporate decision-making and fits within a company’s business incentives of profit maximization and competition.