The US DoJ announces changes to its antitrust compliance program policy which include increased leniency for companies with robust compliance programs

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In a historic shift, prosecutors with the US Department of Justice's (DOJ) antitrust division (the "Division") will now consider providing credit in the charging and sentencing stages of an antitrust criminal investigation to a company that maintains a robust and effective antitrust compliance program. The Division has published guidance entitled "Evaluation of Corporate Compliance Programs" ("Guidance") [1], which sets forth the nine factors that Division prosecutors will evaluate in considering whether a compliance program is sufficient to support a reduction of criminal charges and sentences. The Guidance also provides transparency and useful instruction to the business community and practitioners regarding what the Division considers best practice in antitrust compliance.

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  • Norton Rose Fulbright (New York)
  • Norton Rose Fulbright (New York)

Quotation

Robin Adelstein, Gerald Stein, The US DoJ announces changes to its antitrust compliance program policy which include increased leniency for companies with robust compliance programs, 11 July 2019, e-Competitions July 2019, Art. N° 96753

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