The US DOJ changes course and announces that It will favorably consider “Robust” antitrust compliance programs at both the charging and sentencing stages in criminal cases

Benjamin Franklin once observed that “an ounce of prevention is worth a pound of cure.” In the antitrust context, this means that most, if not all, companies will want as a matter of course to adopt and maintain an antitrust compliance program, because doing so will help avoid antitrust problems before they occur. Until recently, however, the U.S. DOJ Antitrust Division gave no weight to corporate antitrust compliance programs at the charging stage of criminal cases, and provided little public guidance as to how they would be considered at the sentencing stage of such proceedings. As former Deputy Assistant Attorney General Brent Snyder noted in 2014, there were once two hard truths about compliance programs. The first was that the “existence of a compliance program almost never allows

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  • Orrick, Herrington & Sutcliffe (San Francisco)

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Howard M. Ullman, The US DOJ changes course and announces that It will favorably consider “Robust” antitrust compliance programs at both the charging and sentencing stages in criminal cases, 16 July 2019, e-Competitions July 2019, Art. N° 107880

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