SPEAKERS: Gabe Imperato, Managing Partner, Broad and Cassel; Judith Waltz, Partner, Foley and Lardner LLP

• Review the original Department of Justice Guidelines for Prosecution of Business Organizations (formerly known as the “Thompson Memo”) and the modifi cation of these policies contained in the “McNulty Memo”
• Discuss the basis leading up to the modfi cation of the “Thompson Memo” related to “cooperation” by business organizations in criminal and civil fraud investigations and waiver of the attorney/client privilege and withdrawal of payment of fees and costs for defense of individual employees
• Address the relationship between the “McNulty Memo” and compliance program effectiveness for business organizations