This past September 9, the compliance world shifted on its axis. There wasn't any fanfare or major network news coverage. But on that day the U.S. Deputy Attorney General, Sally Quillian Yates, issued a memorandum to all divisions of the justice Department (DOJ) with the strong admonition to shift the focus of all investigations of potential corporate wrongdoing to the conduct of individuals. The scope of the change goes well beyond global commerce activity, to include every subject matter of corporate responsibility within the DOJ's jurisdiction — both civil and criminal. Yet the impact on international businesses and their respective legal compliance responsibilities will likely be dramatic.
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