This article postulates that while much has been done (and continues to be done) by antitrust agencies in the antitrust compliance arena (in particular the recent policy change by the U.S. Department of Justice Antitrust Division), there is still much work to be done internationally and greater progress to be achieved. The time truly has come to rethink compliance. The policy objective of antitrust enforcement is generally accepted to be to “have no need to impose fines at all,” so the author argues that the goal of antitrust enforcement agencies should be to take every step to encourage business integrity, and to support good corporate cultures and sincere compliance efforts. The author contends that there are many pressures facing businesses today – and many compliance challenges, both in relation to antitrust and in relation to the myriad of other laws they need to comply with. Most businesses want to “do the right thing” – they want to act with integrity and protect their reputation – they just need to understand how to do that. Agencies, Academia, and Business Organizations need to work together to ensure the compliance message is fully understood.


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