The US Department of Justice has issued an internal memorandum requiring department staff to proactively seek “accountability” from individuals who cause corporate misconduct. According to the memorandum, “[s]uch accountability is important for several reasons: it deters future illegal activity, it incentivizes changes in corporate behavior, it ensures that the proper parties are held responsible for their actions, and it promotes the public’s confidence in our justice system.” Among other things, the memorandum says that, going forward, to qualify for any cooperation credit, a corporation must completely disclose to the Department of Justice all “relevant facts” about individual misconduct. Department of Justice investigations must also “focus on individuals from the inception” of any investigation, and no corporate resolution may preclude criminal or civil sanctions for any individual, absent extraordinary circumstances. Moreover, says the memorandum, no corporate cases should be resolved without a “clear plan” to address related individual cases prior to any statute of limitation expiration. According to the memorandum, when a decision is made not to charge an individual under investigation, such action “must be memorialized and approved by the United States Attorney or Assistant Attorney General whose office handled the investigation, or their designees.”