In November 2024, the DOJ Antitrust Division rewrote its corporate compliance evaluation guidance — expanding scope to civil violations, adding requirements around ephemeral messaging, and making it clear that annual training decks are no longer sufficient. SideNote.ai is the technology that meets the new standard.
The DOJ's updated guidance now instructs prosecutors to investigate whether boards have compliance expertise, hold private compliance sessions, and what information they've reviewed regarding misconduct. That scrutiny flows directly to the GC. Your compliance program needs to be demonstrable, quantifiable, and real-time.
The DOJ's November 2024 guidance explicitly evaluates whether compliance programs are designed to "detect and deter" violations — not just respond to them after the fact. SideNote educates employees on antitrust risk in real time, preventing the prohibited conduct itself. That's the standard now.
The DOJ now specifically asks about company policies on ephemeral messaging, preservation settings, and personal device communications. SideNote's OS-level agent monitors all applications on company-owned devices — catching risk regardless of the platform or whether messages are set to disappear.
Prosecutors now evaluate whether the board has been briefed on compliance program effectiveness. SideNote's dashboard gives you quantifiable prevention metrics — alerts prevented, risk trends by department, education engagement — that translate directly into board-ready reporting.
The updated DOJ guidance now covers civil antitrust violations in addition to criminal. Your compliance program needs to address both. SideNote's models are trained across the full spectrum — from per se criminal violations like price fixing to civil claims like exclusive dealing and MFN clause abuse.
Your VP of Business Development drafts an email to the integration planning team during an active HSR waiting period: "Let's get their team aligned on territory assignments before the deal closes so we can hit the ground running." SideNote coaches her instantly, explaining that territory allocation discussions during the HSR waiting period constitute gun jumping under the Clayton Act. She reads the explanation, understands why the underlying conduct is prohibited, and decides not to pursue the territory coordination until after closing.
Your compliance dashboard logs the prevented alert, anonymized. No surveillance of the individual. When the board asks about antitrust controls, you have quantifiable proof that the system works — exactly the kind of evidence the DOJ's updated guidance expects you to have.
The DOJ's November 2024 update to its Evaluation of Corporate Compliance Programs now instructs prosecutors to assess ephemeral messaging policies, AI monitoring, whistleblower protections, and whether compliance is embedded into compensation structures including clawbacks.
In January 2026, Michigan's Attorney General filed a federal antitrust suit against five oil majors and the API, alleging a decades-long conspiracy to suppress competition. State-level antitrust enforcement is a growing vector of exposure that compounds federal risk.
The consolidated Shale Oil Antitrust Litigation (MDL 3119) names eight major producers, with plaintiffs seeking treble damages and discovery of all executive communications. Private actions often follow regulatory investigations — and the damages multiply by three.
See how SideNote.ai transforms your antitrust compliance program from a policy binder into a real-time prevention engine.
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