U.S. regulators and prosecutors have recently instituted several policies aimed at holding individuals accountable for corporate misconduct. The Yates Memorandum requires corporations to identify and provide evidence against culpable individuals to receive cooperation credit. The FCPA Pilot Program also requires evidence against individuals for lenient treatment. Additionally, the New York DFS Rule 504 focuses on compliance cultures and holds compliance officers accountable, requiring termination of employees not subject to individual actions. These policies demonstrate increased government focus on prosecuting individuals for corporate wrongdoing.