In response to widespread public criticism that the government has been too lenient with executives responsible for corporate crime, Deputy Attorney General Sally Quillian Yates issued tough new guidelines last year for federal prosecutors.

“One of the most effective ways to combat corporate misconduct,” she said, “is by seeking accountability from the individuals who perpetrated the wrongdoing.”

In Wells Fargo, the government may have the perfect test case.

“We should really hold the Department of Justice’s feet to the fire here,” said John C. Coffee Jr., a professor at Columbia Law School who is an expert on white-collar crime. “Do they really mean what they said in that memo? Will they pursue individuals and not just the underlings?”

Wells Fargo’s $185 million settlement with the Consumer Financial Protection Bureau and other agencies hardly puts an end to the matter. Wells Fargo has acknowledged that thousands of employees, under intense pressure to meet aggressive sales targets, opened as many as two million bogus accounts without customers’ knowledge, in some cases forging signatures.