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ARTICLE · 03 MARCH 2015

A New Take On Compliance Programs

Mayer Brown
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Brent Snyder, the Deputy Assistant Attorney General for Criminal Enforcement at the US Department of Justice’s Antitrust Division, recently provided advice on maintaining an effective antitrust compliance program.

United StatesAntitrust/Competition Law
Richard Steuer
Richard Steuer
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Keywords: antitrust, DOJ, compliance,

Brent Snyder, the Deputy Assistant Attorney General for Criminal Enforcement at the US Department of Justice's Antitrust Division, recently provided advice on maintaining an effective antitrust compliance program. Some of the advice is familiar but much of it is new and noteworthy. All of it merits attention.

First, he emphasized the importance of buy-in at the top, and recounted a story about a company in which the CEO and senior executives diligently attended compliance sessions, only to walk out and fix prices regularly. In the eyes of the Justice Department, adequate buy-in from the top requires (i) becoming "knowledgeable" about the compliance program; (ii) committing enough resources; and (iii) assigning the right people to the job.

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