The framework that prosecutors and regulators use to assess a corporation's response to corporate wrongdoing changed forever on June 16, 1999. That day, then-Deputy Attorney General Eric Holder announced DOJ's new principles for the prosecution of corporations.
Cooperating with NYSE Member Reviews
The framework that prosecutors and regulators use to assess a corporation's response to corporate wrongdoing changed forever on June 16, 1999. That day, then-Deputy Attorney General Eric Holder announced DOJ's new principles for the prosecution of corporations. The so-called Holder Memorandum emphasized cooperation with prosecutors and the requirement that corporations make full and voluntary disclosure of wrongdoing if they hoped to avoid or mitigate prosecution. The twin themes of cooperation and disclosure have become the standards by which federal and state prosecutors and regulators now judge a corporation's response to instances of corporate misbehavior.
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