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DOJ’s Antitrust Division Says Compliance Programs Must be Updated to Address Changing Technology

In November 2024, the U.S. Department of Justice Antitrust Division (“Antitrust Division” or “Division”) updated its guidance on how it will evaluate Corporate Compliance Programs when conducting criminal antitrust...more

What Every Multinational Company Should Know About . . . Dawn Raids

In today’s regulatory landscape, dawn raids — surprise, on-the-spot government inspections — have become increasingly prevalent, especially in Europe, Asia, and South America, where regulatory scrutiny is intensifying. In the...more

Disappearing Messages, Unofficial Communications Platforms and Ever-Increasing Scrutiny by Regulators

Corporate use of third-party messaging platforms, including ephemeral messaging tools (which allow messages to disappear), is quite common and has become both a cost efficiency for employers and a convenient way for employees...more

What Every Multinational Company Should Know About … the U.S. DOJ’s Safe Harbor Policy and What the Antitrust Division Requires

In October 2023, the Department of Justice (DOJ) announced a new Mergers & Acquisitions Safe Harbor Policy (“Safe Harbor Policy”) designed to encourage acquiring companies to voluntarily disclose criminal misconduct...more

Members of Congress Call for DOJ to Investigate Possible Antitrust Violations in Oil Industry

On May 30, 23 Senators signed a letter to the Attorney General, calling on the U.S. Department of Justice’s (DOJ) Antitrust Division to “use every tool” to investigate the oil industry for potential violations of the Sherman...more

What Every Multinational Company Should Know About . . . The Foreign Trade Antitrust Improvements Act

The United States Department of Justice (DOJ) actively enforces the Sherman Act within the U.S. and internationally. Generally described, the Sherman Act is a powerful statutory scheme designed to prohibit anti-competitive...more

Growing Scrutiny of Private Equity in Health Care

The presence of private equity (PE) investment has exploded in recent years in all areas of the health care sector. PE in health care is a good thing when done right: It can pave the way for much needed innovation,...more

Sentencing Guidelines: Third Circuit Rejects Use of “Intended” Loss in Favor of “Actual” Loss

Sentencing in federal fraud cases is driven by loss amounts. To seek a higher sentencing guidelines range, the government often relies on a defendant’s “intended” loss,” rather than the “actual” loss. That approach no longer...more

Procurement Collusion Strike Force Acts Broadly and Often in 2022

In November 2019, the Department of Justice (DOJ) announced the creation of the Procurement Collusion Strike Force (PCSF), an interagency partnership composed of prosecutors from the Antitrust Division and the United States...more

Antitrust Division Announces Update to Its Leniency Program and Revamps Answers to Frequently Asked Questions

On April 4, 2022, the U.S. Department of Justice’s Antitrust Division released updated guidance on its Leniency Program, which protects companies and employees who cooperate with the government from prosecution for their...more

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