In recent years, the Department of Justice’s Antitrust Division (the “Division”) has stepped up its efforts to detect, prosecute and deter violations of the antitrust laws, and has maintained as its “highest priority” combating international cartels that seek to suppress or eliminate competition within the U.S. market.  At the close of FY 2007, the Division had 135 pending grand jury investigations (the highest number since 1992), including more than 50 investigations of suspected international cartel activity.  Thus, it remains as important as ever for companies, especially those that operate in business sectors where they compete against foreign and/or multi-national corporations, to evaluate and update their existing compliance and audit programs.

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