Pre Enron, the DOJ did not have clear guidelines on how to conduct the investigation and prosecution of corporations. Christopher A. Wray and Robert K. Hur, Corporate Criminal Prosecution in a Post-Enron World: The Thompson Memo in Theory and Practice, 43 Am. Crim. L. Rev. 1095, 1000-01 (2006). On June 16, 1999, Deputy Attorney General Eric Holder issued
his memorandum detailing new DOJ policy. Memorandum from Eric Holder, Deputy Attorney General, Department of Justice, to Component Heads and United States Attorneys, Bringing Criminal Charges Against Corporations (June 16, 1999) (