On Sept. 11, 2022, Competition Policy International published an article by Partner Ann O’Brien and Associate Kayley Sullivan titled “Cartels 2022 – Halfway There Update: Policy Shifts, Labor and Trial Losses, and DOJ Not Backing Down... in Fact, Tripling Down.” In the article, O’Brien and Sullivan note that 2022 has so far “been an exceptionally busy time for criminal antitrust enforcement and policy announcements.” They write that “companies and individuals must continue to keep a close eye on potential antitrust risk and shore up their compliance programs to avoid potential criminal investigations and charges.”