Overview
Global Investigations Review quoted Steptoe partner Susan Munro in an article covering a GIR Live Hong Kong symposium on October 17. The session, in which Ms. Munro was a panelist, discussed what impact the Yates Memo – US guidelines published in September requiring companies to hand over all evidence about potential individual wrongdoing to receive cooperation credit – has had on employees facing investigations in Hong Kong and China.
Ms. Munro, head of the firm’s Beijing office, said overall it is too early to see how the Yates Memo will affect investigations in China. She noted that it will be interesting to see what happens in the future as both civil and criminal authorities often tell employees at companies under investigation not to speak to anybody, whereas the memo obligates US companies "to make sure the employees of its Chinese subsidiaries disclose everything.”
The full article can be read at Global Investigations Review (subscription required).