When a possible anti-corruption issue comes to a company’s attention, determining what happened and who was involved is of the utmost importance, but recent DOJ directives may be changing how companies go about getting that information. The Yates Memo and the FCPA Unit Pilot Program, which lay out what companies need to do to receive full credit for cooperating with a government investigation, put a premium on providing information about culpable individuals. Recently, the Anti-Corruption Report and Quinn Emanuel hosted a panel to discuss how these policy statements are changing the way companies – and their employees – approach internal investigations. The panel, moderated by Nicole Di Schino, Editor-in-Chief of the Anti-Corruption Report, included Quinn partners Juan Morillo, Jenny Durkan and Ben O’Neil along with Steve Spiegelhalter, a principal in the fraud investigations and dispute services practice at EY. “The real combined effect of the Yates Memo and the pilot program has, in many ways, an unintended consequence,” Morillo said. “It is going to make individuals more hesitant to cooperate with internal investigations.” See “Internal Investigations and Criminal Discovery After the Yates Memo,” (Apr. 6, 2016) and the Anti-Corruption Report’s three part series on the FCPA Unit’s Pilot Program: “Going Deep on the Fraud Section’s FCPA Pilot Program” (Apr. 20, 2016); “How Will the Fraud Section’s Pilot Program Change Voluntary Self-Reporting?” (May 4, 2016); and “Earning Cooperation Credit Under the Fraud Section’s FCPA Pilot Program” (May 18, 2016).