Fear No Evil: A Compliance and Ethics Professionals' Response to Dr. Stephan

14 Pages Posted: 29 Nov 2011

See all articles by Joe Murphy

Joe Murphy

Independent

Donna Boehme

affiliation not provided to SSRN

Date Written: November 28, 2011

Abstract

How does society prevent cartels? There has been a tendency to rely solely on enforcement and leniency programs, but has this been at the expense of compliance programs? This paper shows how such programs, when done effectively, can work within companies to prevent and detect cartels. However, the current approach of the EU and the US Antitrust Division severely undercut program effectiveness. Dr. Stephan's previous article suggested compliance programs do not work against cartels, but there are factors that indicate that such programs can do much more, if government changes its antagonistic approach to such programs.

Keywords: Antitrust compliance, competition law compliance, cartels, competition law enforcement

JEL Classification: K14, K21, L40, L41

Suggested Citation

Murphy, Joseph E. and Boehme, Donna, Fear No Evil: A Compliance and Ethics Professionals' Response to Dr. Stephan (November 28, 2011). Available at SSRN: https://ssrn.com/abstract=1965733 or http://dx.doi.org/10.2139/ssrn.1965733

Donna Boehme

affiliation not provided to SSRN ( email )

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