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 | 3 min read | 04.17.26
On March 18, 2026, the Antitrust Division (Division) of the U.S. Department of Justice (DOJ) entered into a Non-Prosecution Agreement (“NPA”) with Broadway Across America (“BAA”), resolving a criminal antitrust investigation into agreements between BAA and another entertainment company (“Company A”) that included non-compete restrictions on Company A’s ability to offer potentially competing programming. Notably, the restrictions were contained in a vertical agreement by which BAA presented touring shows at theaters owned by Company A. The announcement is a reminder that the agencies continue to scrutinize non-compete agreements contained in business contracts, and all non-compete provisions, even those included between vertical partners, should be reviewed by antitrust counsel.
Client Alert | 2 min read | 04.16.26
Client Alert | 4 min read | 04.16.26
ROI Tracking as Mens Rea? Novartis Ruling Reframes AKS Pleading Risk
Client Alert | 4 min read | 04.15.26
