4 Steps to Refresh Your Antitrust Compliance Program for the New Year

4 Steps to Refresh Your Antitrust Compliance Program for the New Year


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

The antitrust regulators led an aggressive enforcement agenda in 2015, challenging numerous acquisitions and collecting a record $3.8 billion in fines. In addition, the Department of Justice (DOJ) formally increased its focus on pursuing personal liability for anticompetitive conduct, elevating the risk of potential antitrust exposure for executives and other company individuals. Further, two large disgorgement penalties secured by the Federal Trade Commission in 2015, and other disgorgement collected by the DOJ in previous years, marks an enforcement trend in favor of seeking disgorgement as a remedy for conduct that results in “ill-gotten gains.”

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