Individual Executive Exposure In Government Investigations

A white collar alert from Miller & Chevalier looks at significant cases and government investigations that directly affected executives in the first quarter of 2016. The writers look first at policy, specifically at the Yates Memo and at a new FCPA pilot program that provides financial incentives for companies to self-report all facts related to “involvement in the criminal activity by the corporation’s officers, employees, or agents.” The writers than look at recent criminal actions against executives in a number of categories, including criminal negligence, obstruction, price fixing, bid-rigging, kickbacks and fraud, and fraud involving tax schemes, along with two cases that addressed attorney-client privilege issues in investigations.