on the topic: “If ever there were a time for companies to examine their compliance regimes, this is it.”
Top bosses often escape legal trouble, even when the companies they run pay big penalties. Garland thinks that undermines people's trust in the rule of law. Outliningin how the Department of Justice allocates resources, the AG said he planned to change that, even though it's harder to get individual convictions than settlements with corporations. Wachtell’s memo suggests the firm believes Garland means business.
A defense for those at the top has long been that they didn't know about the misdeeds of rogue actors among their employees and therefore can't be held accountable. Wachtell is now telling CEOs that ignorance isn’t bliss and they need to clean up their corporate acts. For shareholders and regular citizens alike, it’s a long-needed change.