that undermine the Criminal Antitrust Anti-Retaliation Act of 2019, or CAARA, or otherwise interfere with employees’ freedom to report potential crime will cost the employer when the DOJ's antitrust division makes its charging decisions and sentencing recommendations. The DOJ, along with the Department of Labor and the Occupational Safety and Health Administration, said that companies should also be aware that using NDAs to obstruct or impede an investigation may also constitute separate federal criminal violations. "Any company that so interferes with its employees’ cooperation would jeopardize its ability to satisfy its obligations under the Antitrust Division’s leniency policy," the statement said. . . .
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