Yes, Compliance Programs Still Matter

On September 29, 2014, we asked: " Does a Compliance Program Matter to U.S. Antitrust Enforcers?" After concluding that compliance programs still provide tangible benefits, we offered five factors that companies should consider as they develop their own programs.

In the weeks that followed our post, officials from the Criminal Division of the Department of Justice also emphasized the importance of compliance programs. On October 1, Assistant Attorney General Leslie R. Caldwell spoke at an ethics and compliance conference; less than a week later, on October 7, Principal Deputy Assistant Attorney General Marshal L. Miller also provided guidance. Their remarks identify ten hallmarks of effective compliance programs, which we have grouped into four main categories: