On June 1, 2012, WLF called on the U.S. Sentencing Commission to reconsider the important role that corporate compliance programs should play in the antitrust context. WLF expressed its concerns in a letter to Commission Chair Patti Soris in response to the Commission invitation for input on the Commission’s priorities for the upcoming year. WLF cautioned that by not providing companies with an opportunity to receive credit for antitrust compliance programs, the current Guidelines regime actually creates a disincentive for companies to implement such programs altogether. Rather, WLF argued that the Guidelines should, consistent with the Commission’s approach in other areas, encourage and reward effective compliance programs in sentencing determinations for antitrust violations.
