The DOJ's Changing Expectations For Antitrust Compliance

By Renata Hesse, Benjamin Walker and Nicholas Menillo (July 16, 2019, 4:17 PM EDT) -- On July 11, Assistant Attorney General Makan Delrahim announced that the Antitrust Division of the U.S. Department of Justice is reversing its long-standing policy of insisting on guilty pleas for companies involved in criminal violations of the antitrust laws that do not otherwise qualify for leniency under the division's Corporate Leniency Policy.[1] This shift opens a new path to a potential deferred prosecution agreement for companies with "effective" antitrust compliance programs, measured under new guidance issued by the division for evaluating such programs.[2]...

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