Publications & Presentations
September 6, 2019
Polsinelli is pleased to announce Brian Rafferty as a speaker at the American Bar Association 2019 Southeastern White Collar Crime Institute. For more information, please click here
Ethical Guidance in Conducting Internal Investigations: The Intersection of Yates and Upjohn

Friday, September 6, 2019
2:15 PM - 3:30 PM
Château Élan Winery & Resort
100 Rue Charlemagne
Braselton, GA

It has been nearly four years since Deputy Attorney General Sally Yates revised Department of Justice policy to require that corporations provide all relevant facts about individuals involved in corporate misconduct in order to receive credit for their cooperation. This policy increased the pressure on corporations to focus on individual culpability for wrongdoing in pursuing internal investigations and providing information to the government. Our panelists will discuss how this policy has changed the way that companies treat individuals in the course of conducting internal investigations and will address other questions raised by the Department’s increased focus on individual culpability in the context of corporate criminal investigations.