The prompt self-reporting of any involvement in an antitrust cartel will be a key consideration going forward in receiving leniency from the Department of Justice.
The agency’s Antitrust Division on Monday published updates to its leniency policy aimed at “transparency, predictability, and accessibility in criminal enforcement.” Among the changes, a company must now “promptly self-report after discovering its wrongful conduct and undertake remedial measures to prevent reoffending” in addition to cooperating with the division to avoid criminal prosecution.
