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Karen Hoffman Lent and Kenneth Schwartz Karen Hoffman Lent and Kenneth Schwartz

On July 11, 2019, Assistant Attorney General Makan Delrahim announced during a speech at NYU Law School that the Antitrust Division of the Department of Justice has revised its compliance program to “ensure we have the right framework for maximizing deterrence and detection.” U.S. Dep’t of Justice, Office of Public Affairs, Assistant Attorney General Makan Delrahim Delivers Remarks at the New York University School of Law Program on Corporate Compliance and Enforcement, Wind of Change: A New Model for Incentivizing Antitrust Compliance Programs (July 11, 2019) (hereinafter Delrahim, Wind of Change). In light of the way that corporate compliance programs have evolved, Delrahim explained that “the Antitrust Division will: (1) change its approach to crediting compliance at the charging stage; (2) clarify its approach to evaluating the effectiveness of compliance programs at the sentencing stage; and (3) for the first time, make public a guidance document for the evaluation of compliance programs in criminal antitrust investigations.” Id.

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