In their 2012 article, Ted Banks and Joe Murphy argued that as antitrust or competition law had become global, so had the recognition of the importance of antitrust compliance programs. More enforcement authorities had recognized that bona fide programs should be a positive factor in how enforcement authorities treat companies. They urged that the US and other enforcement authorities should follow this approach as a standard of international law. They explained the origin of the focus on compliance programs as a central policy step in preventing organizational crime and misconduct, and how active efforts by government has energized this effort. In the anti-corruption area, for example, promotion of compliance programs was a central goal, with effective programs being recognized as mitigating factors. They also pointed out the anomaly that in antitrust, many enforcers including the US DOJ and the EU’s DG Comp dismissed compliance programs as irrelevant in enforcement decisions, thus equating those companies that made diligent efforts and those who did nothing or even had management fully supporting cartel conduct. They also explained what was needed for an effective compliance program and how antitrust enforcers could make this happen. The decision of the US Antitrust Division in 2019 to recognize compliance programs bears out the thesis of their paper.