Question: Can a company have both an effective antitrust compliance program and an antitrust violation?
DOJ before June 11, 2019: Nope.
DOJ today: Yes, and your company may even get a deferred prosecution agreement if...more
7/15/2019
/ Antitrust Violations ,
Board of Directors ,
Chief Compliance Officers ,
Compliance ,
Corporate Counsel ,
Criminal Antitrust Litigation ,
Deferred Prosecution Agreements ,
Department of Justice (DOJ) ,
Employee Training ,
Incentives ,
Internal Controls ,
New Guidance ,
Recordkeeping Requirements ,
Risk Assessment ,
Risk Mitigation
Key Points:
The FTC is raising the maximum civil penalty that may be imposed for certain violations from $16,000 to $40,000.
For HSR Act violations, where penalties may be imposed for each day the person is in...more
7/1/2016
/ Antitrust Violations ,
Civil Monetary Penalty ,
Compliance ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015 ,
Federal Trade Commission (FTC) ,
FTC Act ,
Hart-Scott-Rodino Act ,
Mergers ,
Premerger Notifications ,
Reporting Requirements ,
Threshold Requirements ,
Unfair or Deceptive Trade Practices