New DOJ Guidance on Antitrust Compliance Programs: Practical Tips and Takeaways for Companies Large and Small

Implementing a Compliance Program That Avoids or Minimizes Antitrust Charges and Sentencing

Recording of a 90-minute CLE webinar with Q&A

Conducted on Wednesday, October 16, 2019

Recorded event now available

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Program Materials

This CLE webinar will examine practical implications of the recent July 2019 U.S. Department of Justice (DOJ) guidance on antitrust compliance policies. The panel will discuss the key elements of an effective antitrust compliance program under the new DOJ guidance, the use of antitrust risk assessments or audits to allocate compliance resources, and the benefits of having a robust antitrust policy.


DOJ recently announced a new policy under which prosecutors will consider whether an organization has an “effective” antitrust compliance program when making criminal antitrust charging and sentencing decisions. The Division also released an updated guidance document which addresses how DOJ will evaluate whether a compliance program is “effective.”

Under the new DOJ guidance, there are several critical elements of a "robust" and "effective" antitrust compliance program that organizations should consider. They include meaningful involvement of senior leadership, compliance efforts tailored to an organization's risk profile, regular training of employees in high-risk positions, appropriate incentives and discipline to deter violations, and regular reevaluation of antitrust risk.

Companies and their counsel should consider using the new guidance as an opportunity to rethink current compliance efforts so that compliance dollars are effectively allocated to high-risk areas in light of current enforcement and litigation trends.

Listen as our authoritative panel examines the new DOJ antitrust guidance and steps companies and their counsel can take now to establish a robust antitrust compliance program.



  1. Current antitrust enforcement climate
  2. Practical takeaways from DOJ’s new policy on antitrust compliance
  3. Key elements of an “effective” antitrust compliance program
  4. Conducting antitrust audits or risk assessments to make the most of compliance spending


This panel will review these and other relevant matters:

  • What kind of business activities present the greatest high antitrust risk?
  • How should a company’s size and risk profile impact the design of its antitrust compliance program?
  • What practical steps can companies and trade associations take now to make their compliance programs "robust" and "effective," per the DOJ guidance?


Allen, Herbert
Herbert F. Allen


Mr. Allen is an experienced litigator and antitrust counselor who helps clients tackle complex problems, both in the...  |  Read More

Andrade, Jessica
Jessica M. Andrade


Ms. Andrade is a commercial litigator and investigations attorney with Polsinelli, where she is chiefly associated with...  |  Read More

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