December 04, 2018

On November 29, 2018, Deputy Attorney General Rod J. Rosenstein announced changes to the U.S. Department of Justice (“DOJ”) policy regarding the investigation of individuals involved in corporate wrongdoing. Although Rosenstein emphasized that pursuing individual wrongdoers remains a “top priority,” the revised policy gives new leeway for companies and prosecutors to focus their investigative efforts on individuals who were “substantially involved” in the misconduct, rather than on every corporate employee who played some role. 

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