Benjamin Sirota

July 25, 2019 | New York Law Journal

This article discusses the principles and criteria that the U.S. Department of Justice's Antitrust Division has indicated will guide its determination of whether to credit a pre-existing compliance program in cartel investigations. It also identifies key takeaways that companies and counsel should keep in mind when assessing the potential implications of this new policy.

By Juan A. Arteaga and Benjamin Sirota

10 minute read

May 01, 2019 | New York Law Journal

This article discusses the principles underlying the Antitrust Division's historical “zero credit” policy toward compliance programs, the implications of recent shifts in this policy, and what broader shifts may be on the horizon. This article also discusses the factors that the Division is likely to find persuasive when determining whether to credit a corporate compliance program.

By Juan Arteaga and Benjamin Sirota

11 minute read