In July 2019, the U.S. Department of Justice Antitrust Division published guidance entitled “Evaluation of Corporate Compliance Programs.” Division prosecutors will now consider providing credit at the charging and sentencing stages of an antitrust criminal investigation to a company that maintains an antitrust compliance program that meets certain specified requirements and where the company self-reports potential violations to the Division. The availability of credit at the charging and sentencing stages will assist in-house counsel in encouraging corporate investment in internal antitrust compliance. However, in-house counsel and company management will also face tough decisions in determining whether the availability of credit (the “carrot”) is worth the risks that flow from self-reporting to the Division.
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