We usually expect shifts in enforcement priorities when a new political party comes into the White House. But rather than a slight shift left or right, as has happened in the past, there may be a dramatic change in many areas of enforcement, as reflected by the appointments in every federal agency as well as to the cabinet. One area where the changes may be significant would be antitrust enforcement, which is shared between Department of Justice and Federal Trade Commission. Written by Theodore L. Banks
Reversing a decades-old policy that refused to recognize antitrust compliance programs in charging decisions or sentencing recommendations, the Department of Justice Antitrust Division released guidelines that outline what the Division expects to see in a compliance program that would entitle a company to credit for that program. The Division’s approach to compliance programs is now largely consistent with the Federal Sentencing Guidelines, and the rest of the Department of Justice. We’ve summarized the guidelines, and provided a form that you can use to apply the analysis questions provided by the Division to see how they would evaluate your antitrust compliance program. Written by Theodore L. Banks
Partner Ted Banks was featured in an interview with Eric Morehead of NYSE Governance Services on “The Road Ahead for Corporate Compliance. Written by Theodore L. Banks
Partner Ted Banks, along with Eric Hinton, Chief Ethics & Compliance Officer at 7-Eleven, Inc., published an article, ‘The Biggest Compliance Mistake That Lawyers Make,’ in the In-House Access blog Written by Theodore L. Banks
Nearly everyone who has email at work uses it occasionally for personal correspondence. Similarly, many people use their personal email accounts for business communications. Written by Christian Liipfert
A few days ago, the Wall Street Journal published an editorial about the government's case against Apple for price fixing of e-books. Written by Theodore L. Banks
Woodman’s Food Market is a chain of warehouse-style grocery stores in Wisconsin. As such, its sales strategy was similar to that employed by Costco and Sam’s Club: the ability to purchase groceries at lower prices by purchasing in large size containers. Written by Theodore L. Banks
On December 2014, a 57-page complaint filed by the U.S. Attorney in Manhattan sought to impose personal liability on the former compliance officer for MoneyGram International, Thomas Haider. It alleges that he willfully or recklessly failed to stop money laundering activities. Written by Theodore L. Banks
