Crediting Corporate Compliance Programs in Criminal Antitrust Cases: How Strong a Wind of Change?

This article examines the U.S. DOJ’s 2019 revision to the Principles of Federal Prosecution of Business Organizations related to antitrust compliance programs, concerns about the revision’s possible effects on the U.S. DOJ’s corporate leniency policy, and the likelihood that the revision will lead to meaningfully different enforcement and sentencing outcomes for companies with antitrust compliance programs. The authors argue that concerns that the revision will negatively impact