by Nana Wilberforce, Lauren Ige, John W. O’Toole, and Esperanza Gilbert
From Left to Right: Nana Wilberforce, Lauren Ige, John W. O’Toole, and Esperanza Gilbert. Photos courtesy of Wilmer Cutler Pickering Hale and Dorr LLP.
Active until its final day in office, the Biden administration focused intently on antitrust compliance programs. Most recently, antitrust enforcers made significant policy changes to their approach to evaluating corporate compliance programs, the use of artificial intelligence (AI) and algorithmic tools, information sharing, competitor collaborations, and labor enforcement. The incoming Trump administration will bring in new antitrust leadership with new priorities, but companies should nonetheless organize their compliance programs and business activities with the recent updates in mind, at least until the Trump administration signals a change in approach. Below, we outline some of these key policy changes and how companies can prepare.