Any thought that the financial crisis might lead to lax antitrust enforcement appears to have been quashed by recent DOJ activity. The Antitrust Division has collected nearly $1 Billion in criminal fines in the first four months of 2009, one of the highest totals ever. And in 2008, the average prison sentence for American offenders reached 25 months. The average for foreign nationals was 18 months. Moreover, in a mid-April posting on its website, the Division expresses concern that stimulous spending may increase collusion. “The potential risk of fraud and collusion increases dramatically,” the Division contended, “when large blocks of funds, such as those associated with the Recovery Act are quickly disbursed.” The leading antitrust law firm, Akin Gump, is advising its clisents that “[t]o avoid an investigation or enforcement action, any company competing for projects funded by the Recovery Act mus avoid all appearance of collusion or other anti-competitive actions. Most importantly, companies must avoid any actions that might lead to inferences of bid-rigging, market allocation, price-fixing or other anti-competitive behavior.”