During a November 29, 2018 speech, Deputy Attorney General Rod Rosenstein announced changes to Department of Justice (“DOJ”) policy concerning individual accountability in corporate cases. The announcement followed the DOJ’s year-long review of its individual accountability policies and the September 2015 memorandum issued by then-Deputy Attorney General Sally Yates, commonly known as the “Yates Memo.”
While making clear that pursuing individuals responsible for corporate wrongdoing remains a top priority in every investigation conducted by DOJ, Mr ...
Both the Department of Justice and the Department of Health and Human Services Inspector General have long urged (and in many cases, mandated through settlements that include Corporate Integrity Agreements and through court judgments) that health care organizations have "top-down" compliance programs with vigorous board of directors implementation and oversight. Governmental reach only increased with the publication by DoJ of the so-called Yates Memorandum, which focused government enforcers on potential individual liability for corporate management and directors in ...
As many pundits speculate regarding the future of the Yates Memo[1] in a Trump administration, on Wednesday, November 30, 2016, Department of Justice ("DOJ") Deputy Attorney General, Sally Q. Yates, provided her first comments since the election. The namesake of the well-known, "Yates Memo," Yates spoke at the 33rd Annual International Conference on Foreign Corrupt Practices Act in Washington, D.C. and provided her perspective on the future of DOJ's current focus on individual misconduct.
Yates, who has served at the DOJ for over twenty-seven years, stated that while the DOJ has ...
Recent Updates
- When AI Becomes Part of Medicine: Why CMS’s AI Questions Matter Now
- Watch: Gender-Affirming Care: What Health Care Providers Need to Know About Federal Enforcement – Thought Leaders in Health Law
- Executive Order 14321 at One Year: Civil Commitment Policy Shifts and Provider Impact
- Watch: FDA’s 2026 Enforcement Priorities: What In-House Counsel Must Know – Thought Leaders in Health Law
- The Future of 340B: New Bills Offer Competing Solutions to Modernize the 340B Drug Discount Program