Major DOJ Antitrust Policy Shift On Immunity For Employees
Law360, New York (January 27, 2017, 12:55 PM EST) -- Cale A. Johnson
Howard B. Iwrey
Cody D. Rockey
In the last week of the Obama administration, without any fanfare, the U.S. Department of Justice’s Antitrust Division included a significant policy shift in an updated version of its “Frequently Asked Questions About the Antitrust Division’s Leniency Program and Model Leniency Letters.” When read in conjunction with the Yates memorandum’s enhanced focus on prosecuting culpable individuals, this policy change has a number of real-world implications that could affect the calculus of any corporation applying for leniency under the Antitrust Division’s corporate leniency policy.
Updated FAQs Eliminate Guaranteed Immunity for Cooperating Employees of...
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