CPI Antitrust Chronicle June 2015 (2) There is another immediate and practical reason for adopting screens as part of a compliance program. A compliance program, with the use of screening, helps position a company to win a race for leniency. A leniency program offers tremendous benefits to implicated companies, potentially permitting them to avoid liability altogether if certain requirements are met. Even if a company fails to qualify for leniency because it is not the first in the door, the DOJ considers “early acceptance of responsibility and meaningful cooperation” in determining the appropriate consequences.54 Given the scores of enforcement regimes that have similarly adopted leniency programs, or that otherwise heavily credit early cooperation, such detection offers tremendous benefits. And, as noted earlier, in the course of uncovering a bid‐rigging scheme, a company may also be able to uncover bribery conduct. Such early detection may allow them to remediate or seek mitigation from the relevant anti‐corruption enforcer s in a timely manner. The ability to be the first to detect the conduct offers tremendous advantages to both companies and enforcers. Beyond their utility to detect anti‐competitive or corrupt schemes, screens can serve as a powerful tool for deterrence. Once knowledge of their implementation spreads, the existence screens alone can have a chilling effect on would‐be offenders. And, in the words Benjamin Franklin, “an ounce of prevention is worth a pound of cure.” others noting that the “implementation of screens as part of compliance programmes can be especially effective because the screening exercise can rely on internal company data which is not necessarily always available to competition agencies” , available online at http://www.oecd.org/daf/competition/exofficio‐ cartel‐investigation‐2013.pdf. 54 Bill Baer, Assistant Attorney General, Antitrust Division, DOJ, Remarks as Prepared for the Georgetown University Law Center Global Antitrust Enforcement Symposium 5‐6 Sept. 10, 2014 , available online at http://www.justice.gov/atr/public/speeches/308499.pdf. 18 .