According to the Yates Memo, who may be held liable for corporate misconduct?

According to the Yates Memo, individual actors implicated in corporate misconduct may be held liable for their actions. This memorandum emphasizes the importance of accountability at the individual level within organizations, signaling a departure from a focus solely on corporate liability. It outlines that companies under investigation for misconduct should provide information about individuals involved to receive potential cooperation credit. This approach aims to deter misconduct by making it clear that individuals, not just the corporations they work for, can face legal consequences for their actions. The memo underscores the accountability of individuals in fostering a culture of compliance within organizations and encourages companies to take proactive measures to prevent misconduct.