In yet another major compliance development, the Justice Department announced the adoption of a new policy to credit effective compliance programs in resolving criminal cartel prosecutions against corporations.  Since the 1990s, the Antitrust Division’s policy regarding corporate compliance programs was generally fixed given the ability of companies to seek benefits under the leniency program.  In this respect, the first reporting company would earn immunity and...

We often read articles and blog postings about anti-corruption, anti-money laundering, export controls and sanctions compliance issues. The focus on these topics is justified. However, there is one glaring omission – antitrust compliance programs. There are a number of reasons for this omission. First, the Justice Department’s Antitrust Division has been slow to credit companies for their compliance programs. For many years, the Antitrust Division...