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ARTICLE · 22 JULY 2019

Compliance Now Counts In AntiTrust

Gardiner Roberts LLP
Gardiner Roberts LLP
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The US Department of Justice announced on July 11 that when organizations implement programs specifically to ensure antitrust compliance

CanadaAntitrust/Competition Law
Kenneth Jull
Kenneth Jull
Nicole Spadotto
Nicole Spadotto
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The US Department of Justice announced on July 11 that when organizations implement programs specifically to ensure antitrust compliance, these programmes will now be rewarded in the Antitrust Divisions' decisions regarding enforcement of criminal antitrust. For the first time, the Division will consider compliance at the charging stage in criminal antitrust investigations, a change which is reflected in the Justice Manual. The Division also announced revisions to its Manual and published a document to guide prosecutors' evaluation of corporate compliance programs at the charging and sentencing stage.1

Assistant Attorney General Delrahim stated, "In an ideal world, corporate compliance programs prevent wrongdoing altogether. If violations do occur, robust compliance programs should lead to prompt detection, which not only nips the conduct in the bud earlier, minimizing the harm to consumers, but also gives companies the greatest chance of winning the race for

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