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Expert Analysis

Lightning Strikes Twice: DOJ Gives 2nd Compliance Credit

Law360, New York ( October 15, 2015, 10:29 AM EDT) -- In the past, getting credit from the Antitrust Division of the U.S. Department of Justice for an effective compliance program was as likely as lighting striking the same place twice. Now, with a recent filing by the DOJ related to a plea deal it struck in September, it appears that has actually occurred. The DOJ has awarded another credit against a criminal fine under the federal sentencing guidelines in response to company efforts to implement or improve a compliance program. Compliance credit may now be in the forecast for companies that find themselves embroiled in a cartel investigation but move swiftly and decisively to address the precipitating circumstances....

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