Corporate Compliance Update: New DOJ Policy Incentivizes Antitrust Compliance

Corporate Compliance Update: New DOJ Policy Incentivizes Antitrust Compliance 850 400 Marketing Team
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As a leader in corporate compliance program design, planning, and implementation, HaystackID recognizes the importance of the recent announcement by the Department of Justice’s Antitrust Division regarding the Division’s new policy for incentivizing antitrust compliance. Provided below for your convenience is a copy of the recent press announcement of this new policy as well as a copy of the guidelines for prosecutors’ evaluations of corporate compliance programs at the charging and sentencing stage. Additionally, please contact HaystackID today to schedule a discussion on how our compliance and eDiscovery offerings may contribute to your organization’s ability to address guidance in the recent DOJ policy update.

Department of Justice Press Announcement

Antitrust Division Announces New Policy to Incentivize Corporate Compliance

During remarks today [July 11, 2019], Assistant Attorney General Makan Delrahim announced the Antitrust Division’s new policy for incentivizing antitrust compliance. 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.

“The Antitrust Division is committed to rewarding corporate efforts to invest in and instill a culture of compliance,” said Assistant Attorney General Delrahim. “The Division’s Leniency Policy has long provided the ultimate credit for effective antitrust compliance programs. Beyond leniency, recently we have credited prospective compliance efforts at sentencing. Crediting compliance at charging is the next step in our continued efforts to deter antitrust violations and reward good corporate citizenship. We also remain dedicated to predictability and transparency. As such, in concert with today’s policy changes, the Division issued a public guidance document that outlines what prosecutors look for when evaluating antitrust compliance programs.

The Justice Manual previously explained the Antitrust Division’s policy “that credit should not be given at the charging stage for a compliance program.” That text has been deleted.

The Division also updated its Manual. The revisions address evaluating compliance programs at the charging and sentencing stage, and Division processes for recommending indictments, plea agreements, and selecting monitors.

For the first time, the Division also published a guidance document that focuses on evaluating compliance programs in the context of criminal violations of the Sherman Act. It is intended to assist Division prosecutors in their evaluation of compliance programs at both the charging and sentencing stage of investigations, and to provide compliance officers and the public greater transparency of the Division’s compliance analysis. To that end, it contains two sections: the first relates to evaluating antitrust compliance programs at the charging stage, and the second addresses compliance considerations at sentencing.

Read the complete announcement at Antitrust Division Announces New Policy to Incentive Corporate Compliance

Evaluation of Corporate Compliance Programs in Criminal Antitrust Investigations – July 2019

Evaluation of Corporate Compliance Programs in Criminal Antitrust Investigations – July 2019 (PDF)

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HaystackID has an experienced and proven corporate compliance and eDiscovery consulting team with deep expertise in areas ranging from proactive corporate compliance to complete managed eDiscovery programs. Contact us today to learn more about how our Forensics First, Early Case Insight, and ReviewRight offerings can be applied to corporate compliance design, planning, and implementation to help in the achievement quality compliance and eDiscovery outcomes at a fair and predictable price.

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