In July 2019, the Department of Justice’s Antitrust Division announced an important and significant change to its treatment of corporate antitrust compliance programs. In a departure from precedent, the Division announced that it would begin giving credit to companies with robust antitrust compliance programs at both the investigation and sentencing phases and also announced that it would be publishing guidance on how it would investigate criminal antitrust violations. One clear message resounds: there is no one-size-fits-all solution. In this article, the authors discuss the history of the

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