Individual and senior accountability: a global trend in enforcement

Author: IFLR Correspondent | Published: 23 Apr 2019

The backlash from the 2008 global financial crisis continues to emerge. Senior accountability and individual responsibility have steadily risen in prominence for regulators and enforcement agencies around the world, and high-profile enforcement actions mean it is now a board-level issue.


According to the Fraud Section at the US Department of Justice (DoJ), 406 individuals were charged criminally in various corporate enforcement actions in 2018, as compared to 301 in 2017, 300 in 2016, and 225 in 2015. Of those, 31 individuals were charged with offences under the Foreign Corrupt Practices Act (FCPA) in 2018, as compared to 24 in 2017, and 17 in 2016. These upward trending numbers appear to indicate that the Yates Memo directive to hold individuals accountable for corporate wrongdoing has gained traction within the DoJ over the last three years.

Issued in September 2015, the Yates Memo announced several policy changes designed to strengthen...