The US Department of Justice (DOJ) Antitrust Division announced significant guidance updates to its leniency program on April 4, 2022. Under the program, companies that self-report antitrust conspiratorial activity to the government (and then fully cooperate with the government in its investigation) can receive immunity from the significant fines—and criminal sentences—imposed under the antitrust laws and a de-trebling of civil fines after meeting certain requirements. These new updates, the first in five years, come in the form of nearly 50 new guidance FAQs addressing the Antitrust Division’s practices, and expectations, for leniency applicants. The DOJ has repeatedly described the leniency program as “its most important investigative tool for detecting cartel activity.” Antitrust
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