McGuireWoods Chicago Office Managing Partner Amy Manning, as quoted by Law360, said it can be a “nightmare scenario” when a client considers
applying for the Department of Justice’s antitrust leniency program without knowing whether the DOJ will perceive the self-reported conduct as an antitrust
violation (of Title 15) – or a non-antitrust violation (often, of Title 18), which may not qualify for leniency.
Amy made the comment while serving on a panel with the deputy assistant attorney general for the Antitrust Division, at an annual meeting of the Antitrust
Section of the American Bar Association. Full text of the April 7 Law360 article, titled “Antitrust Leniency Isn't Absolution, DOJ Official Says,”
is available to subscribers online.