For decades, the Antitrust Division refused to give corporate defendants credit for having an effective antitrust compliance program because if the company was being prosecuted, the compliance program did not work. In July, 2019, the Division announced a new policy and released a guidance statement that set out a comprehensive evaluation of the elements of an effective compliance program. The most difficult issue with the Division’s guidance statement is the evaluation of the conduct of senior company executives in (A) establishing and supervising the compliance program, (B) monitoring and

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