Which principle does the Yates Memo primarily emphasize regarding corporate wrongdoing?

The Yates Memo, formally known as the "Individual Accountability for Corporate Wrongdoing" memorandum, places a strong emphasis on the principle that individuals involved in corporate misconduct are to be held accountable, and that they should be prosecuted before the organization itself faces any charges. This reflects a significant shift in enforcement priorities, aiming to enhance individual accountability within corporate structures.

By focusing on prosecuting individuals, the memo encourages companies to foster a culture of compliance and ethical behavior. This policy aims to deter wrongdoing by making it clear that those directly responsible for illegal actions will face consequences, rather than allowing organizations to escape liability through fines or settlements without addressing the actions of individuals.

This principle underscores a fundamental aspect of corporate governance — that accountability starts at the top with individuals, rather than solely evaluating or penalizing the organization as a whole. The emphasis on individual prosecution is intended to promote responsibility and to ensure that those who make decisions that lead to wrongdoing are held accountable for their actions.