As Risk to Executives Increases, So Does the Need for an Effective Antitrust Compliance Program

As Risk to Executives Increases, So Does the Need for an Effective Antitrust Compliance Program


By: Bernard (Barry) A. Nigro Jr. Maria R. Cirincione

The Antitrust Division of the Department of Justice is considering new guidance from Deputy Attorney General Sally Quillian Yates directing Department attorneys to focus on individual culpability in corporate investigations, including in the civil context.The Department also recently hired an expert to evaluate company compliance programs in criminal matters, showing “just how seriously” the Department takes compliance.In parallel, the Antitrust Division recently has shown signs of a potential policy shift in favor of considering company compliance programs at the sentencing phase.These developments signal a heightened risk of antitrust liability for corporate individuals and serve as a stark reminder about the importance of an effective antitrust compliance program.
 

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