Tuesday, May 26, 2015

1 Small Provision For Barclays, 1 Big Step For Compliance

Mark Rosman (Wilson Sonsini), Danny Sokol (University of Florida and Wilson Sonsini) and Jeff VanHooreweghe (Wilson Sonsini) have a Law 360 article (subscription required) on 1 Small Provision For Barclays, 1 Big Step For Compliance.  The article begins

For the first time, the Antitrust Division of the U.S. Department of Justice has awarded a company sentencing credit for implementing an effective compliance program after the start of an investigation. Getting credit for compliance efforts should not be as hard as space travel, but up until last week, a company’s chances for getting any credit (short of being the winner-takes-all leniency applicant) were no better than landing on the moon.


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