On July 11, 2019, Assistant Attorney General Makan Delrahim announced changes to the Justice Manual designed to incentivize the implementation and use of antitrust compliance programs. [1] Chief among these changes is a reversal of the Antitrust Division’s longstanding policy of refusing to consider compliance programs in charging decisions. At the same time, the DOJ published new guidance on the “Evaluation of Corporate Compliance Programs in Criminal Antitrust Investigations” (the “Criminal Division Compliance Guidance” to assist Division prosecutors in evaluating compliance programs at the charging and sentencing stage of investigations.) Historically, the Antitrust Division’s Corporate Leniency Policy has granted amnesty to the first – and only the first – corporation to self-report an
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The US Assistant Attorney General Delrahim announces changes to the Justice Manual designed to incentivise antitrust compliance programs
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