All That Glitters – A Look Back at the Antitrust Division’s Evaluation of Corporate Compliance Programs and What to Expect

In July 2019, the Antitrust Division issued the first written guidance for the evaluation of corporate antitrust compliance programs. Also, for the first time, the Division noted that a robust compliance program would be considered at the charging stage meaning a company could receive favorable treatment based on its compliance program. The Division’s new policy took inspiration from the Criminal Division’s existing guidelines. In June 2020, the Criminal Division updated its compliance guide