Horsefeathers and the DOJ Antitrust Compliance Program Guidance

From Vaudeville to the Silver Screen to the Small Screen, the Marx Brothers made an impact wherever people found them. Now Tom Fox and Mike Volkov have wedded their love of the Marx Brothers with their passion for compliance and bring them into the boardroom to help explain and explore the sometimes chaotic world of governance, risk-management, ethics and compliance. In this episode they discuss the movie Horsefeathers and the recently released DOJ Antitrust Division compliance guidance.  Highlights from the podcast include:
  1. Why is this document so significant?
  2. How will the Evaluation be used at the Charging Phase? At the Sentencing Phase?
  3. What is different in this Guidance from the ABC Guidance issued in April by the Criminal Division?
  4. What are some of the key lessons learned for the ABC compliance professional?
  5. How does data analytics from the Antitrust Division Guidance inform ABC compliance programs going forward?
  6. How does the Antitrust Guidance, working in conjunction with OFAC’s Sanctions Enforcement Guidelines and the Criminal Division’s 2019 Compliance Guidance demonstrate the need to break down the silos around compliance?
  7. Where does compliance go from here?
Resources
New Antitrust Compliance Guidance
  1. From Tom Fox-eBook on The Antitrust Division Guidance on an Effective Compliance Program, available on CCI, hereat no cost.
  2. From Mike Volkov-Two-part series on DOJ’s Antitrust Division Announces New Policy for Crediting Corporate Compliance Programs. Part Iand Part 2.
  3. Download a copy of the new Antitrust Division Guidance, here.
Marx Brothers
Horsefeathers-the full movie on YouTube.

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