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Remediation, Compliance, and Restitution Under The New Leniency Policy

BY | February 16, 2023

In April 2022, the Antitrust Division of the U.S. Department of Justice announced revisions to its leniency policy which incentivizes voluntary self-disclosure of criminal misconduct in order to earn non-prosecution…

In April 2022, the Antitrust Division of the U.S. Department of Justice announced revisions to its leniency policy which incentivizes voluntary self-disclosure of criminal misconduct in order to earn non-prosecution protections. In addition to giving greater context about an applicant’s obligations under the policy, the revisions require leniency applicants to promptly self-report misconduct, as well as to use best efforts to remediate the harm caused by the illegal activity before receiving a

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