Hints of a Justice Department policy shift—one that evaluates corporate compliance programs as a potential leniency factor on antitrust cases—has come to fruition with announcements made Thursday.
The moves shouldn’t be much of a surprise for those who attended the Compliance Week 2019 conference in May. Principal Deputy Associate Attorney General Claire McCusker Murray tipped off attendees that such changes were in the offing. The Division, she said, was “looking to do more to award and incentivize good corporate citizenship” and “preparing to take into account how much companies invest in their compliance function in leniency evaluations.”

