CORPORATE CRIMINAL PROSECUTION IN A POST-ENRON
WORLD: THE THOMPSON MEMO IN THEORY AND PRACTICE
The Thompson Memo states that “[t]he main focus of [its] revisions is increased
emphasis on and scrutiny of the authenticity of a corporation’s cooperation” with government investigations......purporting to cooperate with a Department
investigation,” has in fact been engaging in conduct that “impede[s] the quick and
effective exposure of the complete scope of wrongdoing.......