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Joseph Spinelli: Yes, the Yates Memo is a watershed event

Career prosecutor and current Deputy AG Sally Yates authored one the most important DOJ policy papers in decades — the Yates Memo, also known as the DOJ’s Individual Accountability Policy.

The September 2015 Yates Memo can be downloaded here (pdf).

To get a better idea of the impact the Yates Memo will have on corporate and individual prosecutions, I spoke with Joseph Spinelli.

He’s a Senior Managing Director at Kroll, based in New York City.

Joe served as the first Inspector General for New York State and before that as a Special Agent of the FBI.

During more than 30 years in private and public service, he’s been on the front lines of FCPA enforcement and compliance, monitorships, and numerous white-collar investigations.

Joe’s take on the Yates Memo? It’s a watershed. It moves the focus from corporate to individual prosecutions and shifts incentives to the C-suite and boards to cooperate in criminal and civil enforcement actions.

Here’s our conversation this week in New York City:


Richard Bistrong is a contributing editor of the FCPA Blog and CEO of Front-Line Anti-Bribery LLC. He was named one of Ethisphere’s 100 Most Influential in Business Ethics for 2015. He consults, writes and speaks about compliance issues. He can be contacted by email here and on twitter @richardbistrong. He’ll be a speaker at the FCPA Blog NYC Conference 2016.

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