On 25 October 2022, the European Commission (“Commission”) published a Frequently Asked Questions (“FAQ”) document containing guidance on its cartel leniency programme. The document aims at facilitating leniency applications by providing further transparency, predictability and accessibility to potential leniency applicants. The current Leniency Notice, which was published in 2006, provides that an undertaking will receive immunity from a fine if (i) it reveals its
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