03/20/2022
https://www.congress.gov...
"As I understand it, the Department does not currently have in place a mechanism whereby a company's own compliance program can be taken into account when discussing settlement for illegal cartel activ..."
"Do you think the procedures you have in place are adequate to address that?"
"I do not necessarily hear you saying that there is a legitimate purpose for the practice. Do you think there is? Should it be abandoned altogether?"
"I suspect that this happens a fair amount because they want to obtain a larger fine."