By Donald C. Klawiter –
This article reviews the history and success of the Leniency Policy and the actions that have caused the apparent decline in leniency and antitrust criminal enforcement. It then offers three recommendations to revive and renew the Policy: (1) establishing a constructive dialogue between the Division leaders and cartel defense bar leaders to harmonize existing controversies in the Division’s Frequently Asked Questions and the Leniency Policy generally, so tha
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