Joe and Donna Boehme have posted this article on the Social Science Research Network.  It is a response to an article by Professor Andreas Stephan questioning whether antitrust compliance programs are effective in dealing with cartels.  Joe and Donna explain why antitrust programs can work for this purpose, but are seriously undercut by the negative approaches of the US Antitrust Division and the European Commission.  Murphy & Boehme, “Fear No Evil: A Compliance and Ethics Professionals’ Response To Dr. Stephan,” http://ssrn.com/abstract=1965733