yates memo

The More Things Change – The More They Stay The Same

By Susan Kohn Ross

Originally published by the Journal of Commerce in January 2016

In writing this article, it was interesting to look back and see whether the old crystal ball was accurate in its predictions in earlier years. Truthfully, the expectation was the old themes were similar over time, and that turned out to be the case. Those earlier articles made clear, the challenges facing businesses in the context of import and export remain complex. By way of example, one constant theme is the rising cost of compliance. A related theme has to do with the expanding complexity of issues demanding compliance efforts. (more…)

DOJ Sets Its Sights on Directors and Officers

By Susan Kohn Ross

Originally published in September 2015.

Whether publicly traded or privately held, corporate boards have been put on notice – the Department of Justice (Justice or DOJ) is after you! On September 9th, DOJ issued a memo entitled: Individual Accountability for Corporate Wrongdoing. In it, Main Justice made clear to all offices that any activity which involves the potential for liability on the part of a corporation can and must also focus on the potentially culpable individuals. (more…)