On November 30, 2016, Deputy Attorney General Sally Yates delivered remarks at the International Conference on the Foreign Corrupt Practices Act. Yates stated that “we cannot forget that behind every bribe and illegal payment is one or more individuals who knew what they were doing was wrong and nonetheless broke the law,” and noted the need to “ensure that whoever is responsible is held accountable.” Yates added that “the best way to deter individual conduct is the threat of going to jail.” Yates then stated that the DOJ’s “heightened focus on individuals extends beyond the FCPA arena,” and described the ways in which—since the publication of the Yates Memo—the DOJ has ensured that both civil and criminal attorneys at the DOJ are “focused on individuals from the very beginning of an investigation.” Yates announced the creation of a new website, https://www.justice.gov/dag/individual-accountability, as part of the DOJ’s effort to provide guidance concerning the DOJ’s policies aimed at gathering information about individual wrongdoers. Looking toward the new administration, Yates noted that in “51 days, a new team will be running the department, and it will be up to them to decide whether they want to continue the policies that we’ve implemented in recent years.” Yates stated that she is “optimistic.” Yates added: “I expect that, in coming months and years, when companies enter into high-dollar resolutions with the Justice Department, you’ll see a higher percentage of those cases accompanied by criminal or civil actions against the responsible individuals.” DOJ Press Release
