DOJ Makes Giving Up Harder: Stricter Requirements for Seeking Leniency

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This article outlines the Department of Justice Antitrust Division ("DOJ") updates its Leniency Program. The DOJ issued a revised set of frequently asked questions ("FAQs") about the program. The changes increased the requirements for individuals and companies seeking leniency from prosecution for their involvement in an antitrust conspiracy by requiring applicants to "promptly" self-report violations and remediate any resulting harm.