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The U.S. Department of Justice has recommended a significantly reduced fine for an auto parts defendant accused of bid-rigging and price-fixing, based largely on the defendant's having quickly instituted a rigorous antitrust compliance program – even though only after the government initiated its investigation. The case is United States of America v. Kayaba Industry Co. An important example for other companies, DOJ's sentencing memorandum lays out what the government considers to constitute a rigorous antitrust compliance program. This is useful guidance for a company developing a compliance program in any situation. Of course, the best time to implement a compliance program is before there is any government investigation. Background Since

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