The US DoJ announces a new policy aimed at incentivising corporate compliance

Some Early Thoughts On the Division’s New Policy On Corporate Compliance Programs (From a Guy Who Was Admittedly Against This When He Was With the Division)* There has been a great deal of publicity surrounding the Antitrust Division’s recent announcement that a corporation involved in a criminal antitrust violation may get credit for an antitrust compliance program if certain conditions are met. The credit may include a DPA (Deferred Prosecution Agreement: the government reaches a plea agreement with the defendant; files criminal charges in an Information; and defers the entry of the guilty plea for a period of time. If the defendant fulfills its obligations (typically cooperation and a fine), the charges are dismissed without entry of a guilty plea. Also under the new policy, if a

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Robert E. Connolly, The US DoJ announces a new policy aimed at incentivising corporate compliance, 11 July 2019, e-Competitions July 2019, Art. N° 91547

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