The U.S. Department of Justice Antitrust Division will consider individual civil enforcement actions against executives implicated in corporate wrongdoing, according to recent comments by DOJ Assistant U.S. Attorney General Bill Baer. His comments follow a September 2015 memo, "Individual Accountability for Corporate Wrongdoing," issued by DOJ's Deputy Attorney General, Sally Yates. The "Yates Memo" observed that, while corporations have been subject to criminal and civil fines and penalties for fraud and other misconduct, culpable company personnel have not always been held accountable. The Yates Memo appears intended to bridge this gap, and it puts company executives on notice that they individually may be pursued if they violate the law even on behalf of their employer. If the
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