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Andrew Finch and Mastercard Senior Managing Counsel Peter Bernstein Discuss New DOJ Antitrust Compliance Program Guidelines in Compliance & Ethics Spotlight

May 26, 2020

Antitrust Practice co-chair Andrew Finch is featured in an interview in the American Bar Association’s Spring 2020 Compliance & Ethics Spotlight newsletter, “Bringing Life to the DOJ Guidelines on Evaluation of Corporate Compliance Programs in Criminal Antitrust Investigations.” In a Q&A with Peter Bernstein, Mastercard Inc.’s Senior Managing Counsel, Competition Law, Compliance and Policy, Andrew discusses the 2019 guidelines under which the Antitrust Division considers compliance programs in making charging decisions in criminal antitrust investigations, guidelines that he helped develop as the Antitrust Division’s number-two-ranking official in the Division between 2017 - 2019.

Andrew says that he hopes to see more transparency around the role of compliance programs in charging and sentencing decisions now that the guidelines are in place. “That could really give companies, and in-house and outside counsel, useful practical guidance in the design, development and improvement of their own antitrust compliance programs,” Andrew notes.

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