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Proposed Federal Guidelines For Compliance Programs Published For Comment

Client Alert | less than 1 min read | 01.07.04

By our earlier Bullet Point (Oct. 7, 2003), we advised that the US Sentencing Commission was considering substantial revisions to its guidelines for organizations and courts on what constitutes an effective compliance program. The proposed guidelines were published on 12/30/03 (68 FR 75340) for public comment, closing on 03/01/04.

Insights

Client Alert | 4 min read | 07.02.25

FTC Orders Divestitures in Retail Fuel Outlet Deal and Signals a Return to More Standard Remedy Discussions

Merger consent orders are back at the FTC, and the FTC’s most recent action showcases how the current leadership is analyzing divestiture proposals. Last week, the FTC approved a proposed consent agreement in Alimentation Couche-Tard Inc.’s (ACT) acquisition of retail fuel outlets from Giant Eagle, Inc. that paired standard retail divestitures with a “prior notice” requirement that ACT notify the agency of future acquisitions in certain markets regardless of size. This FTC has signaled greater acceptance of remedies than the prior administration, and this most recent consent puts that on display, with Commissioner Meador providing merging parties guidance on designing effective remedies....