Leniency, Whistleblowers, and Compliance

Over the last several years, the U.S. Department of Justice’s Antitrust Division (“the Division”) has deployed new strategies for combating cartels through updates to its leniency program and compliance guidance as well as emphasizing other detection methods such as whistleblowers and complainants. The overarching theme of these changes is increasing the risk of detection by developing investigations outside of leniency while tightening the standards for getting leniency to include