Compliance Hot Spots: New Leniency Rules for Cartel Enforcement + DOJ's Win Against Ex-Goldman Baker + Wilmer Reps Intuit TurboTax in FTC Suit
Companies looking to receive leniency for self-reporting cartel antitrust violations will have to come forward quickly to DOJ.
April 13, 2022 at 05:15 PM
10 minute read
Compliance Hot Spots
Welcome to Compliance Hot Spots, our weekly snapshot on white-collar, regulatory and compliance news and trends. Today, we detail changes to DOJ's leniency policy for cartel enforcement. Plus, what was unique about an ex-Goldman banker's FCPA conviction? Please reach out with tips and feedback. Contact me at [email protected] and @AGoudsward on Twitter.
Jonathan Kanter testifies before the Senate Judiciary Committee during his confirmation hearing to be Assistant Attorney General in the Antitrust Division at the U.S. Department of Justice, on Wednesday, October 6, 2021. Photo: Diego M. Radzinschi/ALM 'Promptness' Now a Key Requirement in DOJ Cartel Leniency Program
Did you just discover that you're potentially part of a criminal antitrust cartel and want to report that information to the government? You better hurry.
The Justice Department's antitrust division recently announced changes to a policy providing leniency to the first individual or company to voluntarily report its involvement in a cartel. The policy is a significant aspect of DOJ's antitrust enforcement regime, incentivizing a "race to the government" to report possible crimes.
The revised policy adds promptness to the list of requirements for leniency, meaning that companies now not only have to be first, but they also have to be quick to receive the benefits of the policy.
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