The French Competition Authority Updates its Leniency Program* Last month, the French Competition Authority (“the Authority”) updated the “Procedural Notice” for its leniency program. (Click here for the 2015 version of the Notice in French and here for the 2009 version of the Notice in English.) As in the U.S., the French leniency program allows enterprises that report cartel activity and cooperate in investigations to avoid fines and other penalties. Subject to certain conditions, the program provides total immunity from fines (Type 1 leniency) for (1) an enterprise that is the first to report an illegal agreement that the Authority previously did not know about; or (2) the first to submit proof of an
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