On November 16, Deputy Attorney General Sally Quillian Yates gave a speech regarding the implementation of the DOJ’s recent policy initiatives relating to the prosecution of individuals outlined in the “Yates Memo,” issued on September 9, 2015.  The speech also discussed the incorporation of these policy initiatives into the U.S. Attorney’s Manual.  The revisions emphasize “the primacy in any corporate case of holding individual wrongdoers accountable”; list steps prosecutors are expected to take to maximize opportunities to prosecute individuals; and clarify that corporations must provide complete information about individuals’ involvement in misconduct as a “threshold hurdle” to receiving any cooperation credit.  Ms. Yates further explained that the revisions to the U.S. Attorney’s Manual also give separate consideration to prompt disclosure in charging decisions and codify internal reporting and approval requirements to improve consistency across DOJ and to track how these policies are implemented.  Ms. Yates further explained that DOJ also implemented a new section in the Manual directing DOJ civil attorneys in corporate cases to follow largely the same principles that now guide criminal prosecutions when pursuing individuals.  Lastly, Ms. Yates discussed the revision to the section on parallel proceedings, which emphasizes regular communications and referral between criminal and civil attorneys handling corporate investigations.  For more information on Ms. Yates’ speech and the revisions to the U.S. Attorney’s Manuals, see our client alert on the topic.