As the third in a triumvirate of releases on compliance programs, the DOJ’s Antitrust Division released its antitrust compliance program guidance in July. This follows the release of the ABC guidance from the DOJ’s Criminal Division in April and the OFAC framework in May. These three documents go a long way in cementing the need for robust and effective compliance for corporations.
In this whitepaper, Tom Fox provides an overview of the Evaluation of Corporate Compliance Programs in Criminal Antitrust Investigations and spends time discussing the elements of an effective antitrust compliance program, sentencing considerations and what this new guidance means for anti-corruption and anti-bribery compliance.
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