On November 2, 2015, the U.S. District Court for the Southern District of Ohio entered judgment against Kayaba Industry Co., Ltd. d/b/a KYB Corporation (KYB), a Japanese manufacturer of shock absorbers, in connection with the company’s plea of guilty to a long-running antitrust conspiracy involving price-fixing, bid-rigging, and market allocation. Although the U.S. Sentencing Guidelines’ formula for calculating Kayaba’s criminal fine yielded a recommended range of $103 million to $207 million, the U.S. Department of Justice Antitrust Division (DOJ) and Kayaba jointly recommended a substantially lower fine of $62 million, with no restitution or term of probation. In justifying this downward departure, DOJ’s sentencing memorandum detailed Kayaba’s prompt implementation of “a comprehensive and innovative compliance policy” that “sought to change the culture of the company to prevent recurrence of the offense,” and emphasized that “[s]enior management’s efforts set the tone at the top and made compliance with the antitrust laws a true corporate priority.” The court accepted the parties’ joint recommendations in imposing its judgment, making the DOJ’s sentencing memorandum a key roadmap for devising, implementing and evaluating corporate antitrust compliance programs.