Leniency

Foreword Leniency & competition law: An overview of EU and national case law

More than 25 years after the adoption of the first European Commission Leniency Notice, the fight against cartels remains at the top of the European Commission’s (“Commission”) priorities, and the 27 European Union (“EU”) national competition authorities (“NCAs” or “CAs”). The economy is facing significant challenges as it needs to recover from the deep crisis caused by the pandemic. That recovery must also be in a way that is consistent with a greener and digital future. In light thereof, the Commission considers it is more important than ever that markets work fairly and well, and that it will take firm action to tackle cartels. Leniency programmes are a crucial tool for uncovering cartels. Historically, a large majority of cartel decisions adopted by European competition authorities is based on immunity and leniency applications. The number of leniency applications is however decreasing. The increasing cost and risk associated with obtaining immunity from different jurisdictions around the world, together with the private enforcement risk, seems to disincentive companies from applying for leniency. The Commission is increasing its focus on the operation of the leniency programme, and has launched regular discussions with business and other competition enforcers to get their views and share experiences.

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Covington & Burling (Brussels)
Covington & Burling (Brussels)

General antitrust

The German Government introduces landmark reforms to the Competition regime with the enactment of the Whistleblower Protection Act
Hogan Lovells (Munich)
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Hogan Lovells (Munich)
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Hogan Lovells (Düsseldorf)
After a long legislative process, the German Whistleblower Protection Act (“the Act” or HinSchG) came into force on July 2. As Hogan Lovells reported several months ago (see article in German here), Germany has, albeit belatedly, thus implemented the EU Whistleblower Directive. The new (...)

The Czechia Government amends its competition law, introducing greater discretion and powers for the national competition authority, clearer rules for fining associations of undertakings, greater protection for whistleblowers, and stricter criteria for settlement
White & Case (Prague)
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White & Case (Prague)
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White & Case (Prague)
Very soon, a long-awaited amendment to the Czech Act on the Protection of Competition will become law, implementing (after a long delay) the requirements of what is known as the ECN+ Directive (an EU directive designed to give greater powers to competition authorities). The primary objective (...)

The Indian Government reforms its competition regime following the enactment of the Competition Amendment Act 2023
Talwar, Thakore & Associates (New Delhi)
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Talwar, Thakore & Associates (New Delhi)
The Competition (Amendment) Bill, 2023 (Amendment) was recently approved by both houses of Parliament in India and thereafter received the assent of the President to become the Competition (Amendment) Act, 2023. It introduces significant substantive as well as procedural changes to Indian (...)

The EU General Court issues a decision which finds that in situations where regional State aid is found to be incompatible with the internal market, their regional handicaps cannot justify any leniency in the recovery of the aid (Zone Franche de Madère)
Maastricht University
Selectivity of Regional Schemes* Introduction Article 107(3)(a) areas and the outermost regions of the EU [defined in Article 349 TFEU] are more favourably treated under State aid rules. But they still have to comply with the terms of Commission authorising decisions. In case regional (...)

The Belgian Government sees the act transposing the ECN+ Directive and introducing several other amendments to competition law and the criminal code enter into force
Ashurst (Brussels)
On 17 March 2022, the Belgian Act transposing the ECN+ Directive and also introducing several other amendments to Belgian Competition law (ie, Book IV of the Code on Economic Law) and the Belgian Criminal Code entered into force. Key takeaways The ECN+ Directive aims to empower EU National (...)

The Belgian Parliament passes a law implementing the ECN+ directive notably reinforcing the leniency program and empowering investigative tools
Van Bael & Bellis (Brussels)
Belgium implements ECN+ Directive and reforms competition rules On 7 March 2022, a law of 28 February 2022 reforming the Belgian competition rules (“Law”) was published in the Belgian Official Journal. This Law, which will enter into force in the coming days, will implement Directive 2019/1, (...)

The Irish Competition Authority announces consultations on policies and guidelines for exercising new competition law powers
Irish Competition Authority (Dublin)
CCPC consultations on policies and guidelines for exercising new competition law powers opening on 14 February* The Competition and Consumer Protection Commission (CCPC) has today announced a series of public consultations on how it intends to use the expanded competition law enforcement (...)

The Greek Government transposes the ECN+ Directive into its national law by amending the Greek Competition Act
Kyriakides Georgopoulos (Athens)
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The new Law 4886/2022 ‘on the Modernisation of Competition Law for the Digital Era’, substantially amends the Greek Competition Act (Law 3959/2011) On 24 January 2022 the new Law 4886/2022 (GG A’ 12/24.01.2022) entered into effect amending the Greek Competition Act and transposing Directive (...)

The Italian Government adopts a Legislative Decree implementing the ECN+ Directive, which in turn provides the Competition Authority with increased enforcement powers
Bocconi University (Milan)
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Hogan Lovells (Milan)
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Hogan Lovells (Milan)
Italy has just enacted the Legislative Decree implementing the ECN Plus Directive so providing the Italian Competition Authority (ICA) with increased enforcement powers. The following sections provide a first overview of the main novelties which include sanctions to natural persons for breach (...)

The Ukrainian Parliament adopts the Tax Amnesty Law which includes amnesty for competition law violations
Redcliffe Partners (Kyiv)
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Redcliffe Partners (Kyiv)
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Redcliffe Partners (Kyiv)
AMNESTY FOR VIOLATIONS OF THE COMPETITION LAW* On 21 July 2021, the Law of Ukraine on Amendments to the Tax Code of Ukraine and Other Laws of Ukraine on Encouraging the De-shadowing of Income and Improving Tax Culture of Citizens by Introducing a One-time (Special) Voluntary Declaration of (...)

The UK Government announces a series of proposed reforms to competition law enforcement aiming to produce a “best in class” competition regime to allow the UK to exploit post-Brexit opportunities
Hogan Lovells (London)
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Hogan Lovells (London)
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Covington & Burling (London)
In what could herald the most significant changes to the UK competition regime in 25 years, the UK Government has announced a series of proposed reforms to UK competition law enforcement. The stated aims of the reforms are to produce a “best in class” competition regime to allow the UK to (...)

The Finnish Competition Authority announces updates to the National Competition Act based on the ECN+ Directive, including changes to the monitoring of competition restraints and sanctions imposed for infringements
Finnish Competition and Consumer Authority (Helsinki)
Changes to monitoring competition restraints and sanctions imposed for infringements – amendments to the Competition Act will enter into force on 24 June 2021* Amendments that apply to the assessment of the penalty payments imposed for infringements have been made to the Competition Act. At (...)

The French President enacts an ordinance finalising the transposition of the ECN+ Directive into national law to strengthen the powers of the national competition authorities and increase their effectiveness
Bird & Bird (Paris)
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Huawei Technologies (Boulogne-Billancourt)
On 26 May this year, a presidential ordinance (the Ordinance) perfected the transposition into French law of the ECN+ European Directive of 11 December 2018, which aims to strengthen the powers of national competition authorities and increase their effectiveness. Several provisions of the (...)

The Spanish Parliament amends the Competition Act to implement the ECN+ Directive
Jones Day (Madrid)
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Jones Day (Madrid)
In Short Background: European Parliament and Council Directive (EU) 2019/1 ("ECN+") required EU Member States to adopt, by February 4, 2021, minimum standards related to national competition authority ("NCA") antitrust enforcement. ECN+ aims to promote cooperation among NCAs and the (...)

The Spanish Parliament transposes the ECN+ Directive into Spanish law
Bird & Bird (Madrid)
On 29 April 2021, the Spanish Royal Decree-Law 7/2021 entered into force, modifying the Spanish Competition Act (“LDC”) due to the transposition of the Directive 2019/1 – known as the “ECN+ Directive” – which aims to achieve a more effective application of competition rules by the National (...)

The Spanish Parliament publishes a decree which greatly amends national competition law as a result of the transposition of the ECN+ Directive
Herbert Smith Freehills (Madrid)
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Herbert Smith Freehills (Madrid)
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Herbert Smith Freehills (Madrid)
On 28 April 2021, Royal Decree-Law 7/2021, of 27 April, was published in Spain’s Official State Journal (RD 7/2021). RD 7/2021 has the aim of transposing into Spanish legislation a number of EU directives, including Directive (EU) 2019/1 of the European Parliament and of the Council of 11 (...)

The Swedish Competition Authority gains new powers and introduces changes after the transposition of the ECN+ Directive
Linklaters (Brussels)
March 2021 marks a new era for the Swedish Competition Authority (SCA - Konkurrensverket). Major amendments to competition legislation in the country have entered into force on March 1st, introducing changes that result in increased powers for the SCA. These new amendments come as fresh air, (...)

The German Parliament enters into force antitrust rules under the 10th amendment to the Act against Restraints of Competition introducing several significant changes
McDermott Will & Emery (Dusseldorf)
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McDermott Will & Emery (Dusseldorf)
New German Antitrust Rules: A Positive Move for Compliance Programs* What has changed? On January 19, 2021, new German antitrust rules entered into force under the 10th amendment Act to the Act against Restraints of Competition (ARC) and introduced a number of significant changes. The Act, (...)

The US Government reforms its criminal antitrust compliance legislation and policies
Fried Frank Harris Shriver & Jacobson (Washington)
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Fried Frank Harris Shriver & Jacobson (New York)
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Fried Frank Harris Shriver & Jacobson (New York)
This article has been nominated for the 2021 Antitrust Writing Awards. Click here to learn more about the Antitrust Writing Awards. Over the past two decades, robust compliance programs have become increasingly important across a wide range of enforcement matters. In addition to helping (...)

The US President signs into law the Criminal Antitrust Anti-Retaliation Act which seeks to protect whistleblowers in criminal antitrust cases
Fried Frank Harris Shriver & Jacobson (New York)
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Fried Frank Harris Shriver & Jacobson (New York)
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Fried Frank Harris Shriver & Jacobson (Washington)
This article has been nominated for the 2021 Antitrust Writing Awards. Click here to learn more about the Antitrust Writing Awards. Having an Effective Antitrust Compliance Program Is More Important Than Ever* Over the past two decades, having robust compliance programs has become (...)

The Lithuanian Competition Authority enters into force its competition act with updates to fining powers and guarantees of independence
Lithuanian Competition Authority (Vilnius)
Lithuanian Competition Law Amendments: From Fining Powers to Guarantees of Independence* On November 1 amendments to the Law on Competition of the Republic of Lithuania enter into force. These amendments are in line with the ECN+ Directive intended to empower the competition authorities of (...)

The Chinese State Administration for Market Regulation issues antitrust guidelines on how companies can avoid administrative penalties and reduce fines in cases of antitrust infringement
Lang Yue (Beijing)
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Zhao Sheng (Beijing)
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Linklaters (Beijing)
This article has been nominated for the 2021 Antitrust Writing Awards. Click here to learn more about the Antitrust Writing Awards. In the summer of 2020, China’s State Administration for Market Regulation (SAMR) published four antitrust guidelines signed-off by the Anti-monopoly Commission (...)

The Spanish Ministry of Economy and Digital Transformation publishes a draft regulation modifying the Competition Act
Callol, Coca & Asociados (Madrid)
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Callol, Coca & Asociados (Madrid)
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Callol, Coca & Asociados (Madrid)
Last 31 July 2020, the Ministry of Economic Affairs and Digital Transformation made public the draft regulation modifying Law 15/2007, of 3 July, on the Defense of Competition (Draft Regulation). The Draft Regulation, other than implementing the main features of the ECN+ Directive into Spanish (...)

The Hong Kong Competition Authority publishes its policy on recommended pecuniary penalties for anti-competitive conduct
Hong Kong Competition Commission (Hong Kong)
Competition Commission publishes Policy on Recommended Pecuniary Penalties for anti-competitive conduct* The Competition Commission (Commission) today published a policy on recommended pecuniary penalties (Policy) for anti-competitive conduct. The Policy outlines the general principles and (...)

The Belgian Competition Authority adopts guidelines regarding the calculation of fines, leniency applications and on the informal opinions of the Competition Authority’s President
Bird & Bird (Brussels)
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Allen & Overy (Brussels)
On 22 May 2020 the Belgian Competition Authority (BCA) published three new guidelines: (i) new guidelines regarding the informal opinions of the BCA’s President; (ii) new guidelines regarding the calculation of fines; and (iii) new leniency guidelines. Below we set out the most important (...)

The Belgian Competition Authority adopts leniency guidelines
Court of First Instance of Namur (Namur)
On 22 May 2020, new Leniency Guidelines (the “2020 Guidelines”) adopted by the Belgian Competition Authority (the “BCA”) were published in the Belgian Official Journal. The 2020 Guidelines replace the 2016 Leniency Guidelines and lay down the conditions to obtain total or partial immunity from (...)

The Hong Kong Competition Authority revises leniency program for cartel conduct
Hong Kong Competition Commission (Hong Kong)
Competition Commission revises leniency programme for cartel conduct* The Competition Commission (Commission) today published a revised Leniency Policy for Undertakings Engaged in Cartel Conduct and a new Leniency Policy for Individuals Involved in Cartel Conduct to enhance the effectiveness (...)

The German Federal Ministry for Economic Affairs and Energy issues an update on the reform of national competition law
Court of First Instance of Namur (Namur)
On 24 January 2020, the German Federal Ministry for Economic Affairs and Energy published an update of its draft 10th amendment to the Act against Restraints of Competition (the “ARC”), officially called the “ARC Digitization Act”. Compared to the initial draft (see VBB on Competition Law, (...)

The Chinese State Administration for Market Regulation issues three new sets of rules and regulations relating to monopoly agreements, abuse of dominant market positions and abuse of administrative power
Orrick, Herrington & Sutcliffe (Beijing)
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Noerr (Dusseldorf)
This article has been nominated for the 2020 Antitrust Writing Awards. Click here to learn more about the Antitrust Writing Awards. September 1, 2019 may be seen as a new starting point for the enforcement of China’s antitrust and competition laws. On this date, three new sets of rules and (...)

The US DoJ announces new approach to incentivizing and evaluating corporate antitrust compliance programs
Arnold & Porter Kaye Scholer (Washington)
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Arnold & Porter Kaye Scholer (New York)
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Arnold & Porter Kaye Scholer (Washington)
This article has been nominated for the 2020 Antitrust Writing Awards. Click here to learn more about the Antitrust Writing Awards. I. Overview On July 11, 2019, Makan Delrahim, Assistant Attorney General for the Antitrust Division (the Division) of the DOJ, announced the Division’s new (...)

The US Assistant Attorney General Delrahim announces changes to the Justice Manual designed to incentivise antitrust compliance programs
Baker Botts (Washington)
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US Federal Trade Commission (FTC) (Washington)
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LCLD Leadership Council on Legal Diversity (Washington)
On July 11, 2019, Assistant Attorney General Makan Delrahim announced changes to the Justice Manual designed to incentivize the implementation and use of antitrust compliance programs. Chief among these changes is a reversal of the Antitrust Division’s longstanding policy of refusing to (...)

The US DoJ announces changes to its antitrust compliance program policy which include increased leniency for companies with robust compliance programs
CPR Institute (New York)
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Norton Rose Fulbright (New York)
This article has been nominated for the 2020 Antitrust Writing Awards. Click here to learn more about the Antitrust Writing Awards. In a historic shift, prosecutors with the US Department of Justice’s (DOJ) antitrust division (the "Division") will now consider providing credit in the (...)

The German Competition Authority publishes an annual report for 2018 and a biannual activity report for 2017/2018
Court of First Instance of Namur (Namur)
On 27 June 2019, the German Federal Cartel Office (“FCO”) published its annual report 2018 and biannual activity report 2017/2018. The reports include statistics on the total amounts of fines, leniency applications and merger pro-ceedings, describe the FCO’s policies and the key cases which (...)

The Hong Kong Competition Authority publishes a cooperation and settlement policy expanding its leniency program
Hogan Lovells (Hong Kong)
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Hogan Lovells (Hong Kong)
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Hogan Lovells (Beijing)
On 29 April 2019, the Hong Kong Competition Commission (’HKCC’) published the Cooperation and Settlement Policy for Undertakings Engaged in Cartel Conduct (’Cooperation Policy’). In essence, the Cooperation Policy expands HKCC’s Leniency Policy, published in November 2015, just before the full (...)

The Hong Kong Competition Authority publishes a cooperation and settlement policy to complement its existing leniency framework
Hong Kong Competition Commission (Hong Kong)
The Commission has published a Cooperation and Settlement Policy for Undertakings Engaged in Cartel Conduct (Cooperation Policy) as a supplement to its existing Leniency Policy for Undertakings Engaged in Cartel Conduct (Leniency Policy) and Enforcement Policy. Under the Cooperation Policy, (...)

The Belgian Parliament transposes the ECN+ Directive into the national legislation and introduces filing fees in concentration notifications
McDermott Will & Emery (Brussels)
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Allen & Overy (Brussels)
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Allen & Overy (Brussels)
On March 7, 2022, changes to both the Belgian Code of Economic Law (CEL) as well as the Belgian Criminal Code (BCC) were published in the Belgian Official Gazette (Belgisch Staatsblad, Moniteur belge). The main changes include: Introducing a filing fee in notifications of concentrations (...)

Leniency and competition law: An overview of EU and national case law
Covington & Burling (Brussels)
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European Commission - DG COMP (Brussels)
More than 20 years after the adoption of the first European Commission Leniency Notice, the detection and sanctioning of cartels remains a key feature of the enforcement agenda of the European Commission (the “Commission”) and – the currently still 28 – European Union (“EU”) national (...)

Anticompetitive practices

The Canadian Competition Authority imposes a fine on two Japanese shipping companies for their role in an international conspiracy that restricted competition for the shipment of vehicles to Canada (Nippon Yusen / Kawasaki Kisen Kaisha)
Canadian Competition Bureau (Gatineau)
NYK and “K” Line fined for international conspiracy to reduce competition in vehicle shipping services to Canada* Japanese shipping companies Nippon Yusen Kabushiki Kaisha (NYK) and Kawasaki Kisen Kaisha, Ltd. (“K” Line) were respectively fined $1.5 million and $460,000 by the Ontario (...)

The UK Competition Authority issues an infringement decision finding that a football club and a sports equipment retailer colluded to restrict competition in the sales of sports-branded clothing and replica kit (Leicester City FC / JD Sports)
Cleary Gottlieb Steen & Hamilton (London)
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Cleary Gottlieb Steen & Hamilton (London)
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Cleary Gottlieb Steen & Hamilton (London)
CMA Fines Leicester City FC for Anticompetitive Pricing Practices* On 31 July 2023, the Competition and Markets Authority (CMA) issued an infringement decision finding that Leicester City Football Club and JD Sports had colluded to restrict competition in the sales of Leicester City-branded (...)

The Lithuanian Competition Authority fines a resale price fixing agreement between certain cosmetic manufacturers and their distributors and fines the participating undertakings (Oda / Garbanė / GSS Baltic...)
Lithuanian Competition Authority (Vilnius)
Price Fixing Between Cosmetic Manufacturers and Their Distributors Prevented Consumers from Getting Cheaper Products* The Competition Council found that Oda LT and six companies distributing its skin care products agreed not to sell Oda LT products to consumers at prices lower than those (...)

The Spanish Competition Authority fines a cartel involving two major companies providing business information database services (Bureau Van Dijk / Informa D&B)
Spanish Competition Authority (CNMC) (Madrid)
The CNMC sanctions the cartel of two of the main companies providing business information database services in Spain* The companies sanctioned are Bureau Van Dijk Publicaciones Electrónicas S.A. and jointly and severally its parent company Moody’s Corporation, and Informa D&B S.A.U. and (...)

The Swedish Competition Authority fines a temperature-controlled transport supplier for market sharing (Norrmejerier Cooperative)
Swedish Competition Authority (Stockholm)
Temperature-controlled transport suppliers fined for prohibited cooperation* When two companies offering temperature-controlled transport divided up customers on the market between themselves, they breached the prohibition on anti-competitive cooperation between undertakings. The Swedish (...)

The Canadian Superior Court of Ontario fines a bread maker with the highest price fixing fine to date for taking part in a criminal arrangement that increased the price of fresh commercial bread (Canada Bread / Weston Foods)
Canadian Competition Bureau (Gatineau)
Canada Bread sentenced to $50 million fine after pleading guilty to fixing wholesale bread prices* Canada Bread Company, Limited was fined $50 million today by the Ontario Superior Court after pleading guilty for its role in a criminal price-fixing arrangement that raised the wholesale price (...)

The Canadian Ontario Superior Court fines a bread-maker $50M for price fixing in the largest fine to date for such conduct (Canada Bread / Weston Foods)
Journal of Parliamentary and Political Law (Ottawa)
Introduction A fine of $50 million represents a lot of bread. That’s the amount levied by the Ontario Superior Court under Canada’s Competition Act (‘the Act’) after Canada Bread Limited (‘Canada Bread’) pleaded guilty in an agreed statement of facts to four counts of criminal price-fixing (...)

The Canadian Competition Authority publishes enforcement guidelines on recently criminalized wage-fixing and no-poach agreements
Baker McKenzie (Toronto)
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Baker McKenzie (Toronto)
In brief The Canadian Competition Act was recently amended to, among other things, criminalize wage-fixing and no-poach agreements between unaffiliated employers. Following a one-year grace period for permitted Canadian employers to ensure they are in compliance, the criminal prohibition (...)

The Canadian Competition Authority publishes a guideline to criminalise wage-fixing and no-poach agreements
Canadian Competition Bureau (Gatineau)
Competition Bureau publishes wage-fixing and no-poaching enforcement guidelines* Wage-fixing and no-poaching agreements will be illegal beginning on June 23, 2023. Today, the Competition Bureau published its wage-fixing and no-poaching enforcement guidelines. The guidelines provide (...)

The UK Competition Authority provisionally finds that 5 banks broke competition law by exchanging information on their trading strategies on UK bonds (Citi / Deutsche Bank / HSBC / Morgan Stanley / Royal Bank of Canada)
UK Competition & Markets Authority - CMA (London)
CMA provisionally finds 5 banks broke competition law on UK bonds* The CMA has provisionally found these banks unlawfully exchanged sensitive information regarding UK government bonds in one-to-one online chats. The Competition and Markets Authority (CMA) has provisionally found that 5 (...)

The Brazilian Competition Authority signs a leniency agreement with a producer of car breaking systems for cooperating with an investigation into an information exchange cartel (Robert Bosch)
Brazilian Administrative Council for Economic Defense (CADE) (Brasilia)
CADE signs agreement in cartel investigation related to international market of braking systems* On the hearing session of 10 May, the Tribunal of CADE signed a cease and desist agreement with the company Robert Bosch GMBH in a case related to a cartel in the international market of braking (...)

The Brazilian Competition Authority enters into a leniency agreement to examine an alleged cartel in printing machine and laminator procurements (Task Sistemas de Computação)
Brazilian Administrative Council for Economic Defense (CADE) (Brasilia)
Office of the Superintendent-General of CADE signs the 108th leniency agreement and launches administrative proceeding* On 23 February, the Office of the Superintendent-General of the Administrative Council for Economic Defense (CADE) signed a leniency agreement with the company Task (...)

The Brazilian Competition Authority enters into a leniency agreement to examine an alleged cartel in graphic printing services procurements
Brazilian Administrative Council for Economic Defense (CADE) (Brasilia)
Office of the Superintendent General of CADE signs the 109th leniency agreement and launches administrative proceeding* On 28 February, the Office of the Superintendent General of CADE signed another leniency agreement within the Brazilian Competition Defence System, reaching 109 signed (...)

The Czech Competition Authority fines two undertakings for price fixing in the market for the distribution of electronic devices and accessories (Beryko / Witty)
Czech Competition Authority (Brno)
THE OFFICE PUNISHES A CARTEL OF XIAOMI ELECTRONICS DISTRIBUTORS DETECTED THANKS TO THE LENIENCY PROGRAM* In its first-instance decision, the Office for the Protection of Competition (hereinafter referred to as “the Office”) imposed a fine of CZK 24,467,000 on Beryko s.r.o. for participating (...)

The Czech Competition Authority sanctions distributors of electronics products for colluding but reduces the penalties as part of the leniency program (Beryko / Witty)
Czech Competition Authority (Brno)
THE OFFICE PUNISHES A CARTEL OF XIAOMI ELECTRONICS DISTRIBUTORS DETECTED THANKS TO THE LENIENCY PROGRAM* In its first-instance decision, the Office for the Protection of Competition (hereinafter referred to as “the Office”) imposed a fine of CZK 24,467,000 on Beryko s.r.o. for participating (...)

The Spanish Competition Authority investigates possible anticompetitive practices in the allocation of travel agency tenders
Spanish Competition Authority (CNMC) (Madrid)
The CNMC investigates possible anti-competitive practices in the allocation of travel agency tenders* These practices consist of agreements for the manipulation and allocation of tenders called by the General State Administration. On 28, 29, 30 and 31 March, the CNMC carried out dawn raids at (...)

The Brazilian Competition Authority enters into two leniency agreements and launches administrative proceedings to investigate cartels in public and private procurements
Brazilian Administrative Council for Economic Defense (CADE) (Brasilia)
CADE’s Office of the Superintendent-General signs two leniency agreements and launches administrative proceedings to investigate cartels* The adherence to agreements indicates the attractiveness of the Brazilian Leniency Programme, which has clear rules following international best (...)

The Luxembourg Administrative Tribunal modifies and upturns the Competition Authority’s fine on a food supplier for resale price maintenance, and affirms the right of a leniency applicant to benefit from the principle of legitimate expectation (Bahlsen / Delhaize / Auchan)
Bonn & Schmitt (Luxembourg)
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Bonn & Schmitt (Luxembourg)
Introduction On 6 January 2015, the Luxembourg Competition Authority (formerly the Competition Council, hereinafter “Authority”) opened an investigation against the food supplier Bahlsen on suspicion of aligning resale prices to consumers. After a search of the supplier’s headquarters on 15 (...)

The EU Commission fines 5 styrene purchasers €157M for price fixing and exchanging sensitive commercial information (Sunpor / Synbra / Synthomer / Synthos / Trinseo / INEOS)
European Commission - DG COMP (Brussels)
Antitrust: Commission fines styrene purchasers €157 million in cartel settlement* The European Commission has fined Sunpor, Synbra, Synthomer, Synthos and Trinseo a total of €157 million for participating in a cartel concerning purchases on the styrene monomer merchant market. INEOS was not (...)

The EU Commission fines five styrene purchasers €157M for fixing prices and exchanging commercially sensitive information and grants a sixth member of the cartel full leniency (Sunpor / Synbra / Synthomer / Synthos / Trinseo / INEOS)
Van Bael & Bellis (Brussels)
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Van Bael & Bellis (Brussels)
On 29 November 2022, the European Commission (the “Commission”) announced that it had imposed fines totalling €157 million on five companies involved in a purchasing cartel concerning styrene monomer (“styrene”) for various periods between 1 May 2012 and 30 June 2018. The five companies fined (...)

The Italian Council of State partially upholds the Competition Authority’s decision to fine undertakings for cartel conduct in the market for production and marketing of corrugated cardboard packaging (Alliabox / Ondulati del Salvio / Sandra / Topazzini)
Herbert Smith Freehills (Milan)
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Herbert Smith Freehills (Milan)
The Consiglio di Stato (the Italian Supreme Administrative Court) has upheld the decision of the Italian Competition Authority ("ICA"), and confirmed the existence of price fixing and market sharing cartels concerning the production and marketing of corrugated cardboard packaging. The (...)

The German Higher Regional Court of Düsseldorf dismisses the appeal of two technical building service providers fined for bid-rigging; and follows the CJEU precedent to hold that the limitation period for the prosecution of bid-rigging cartels begins at the point the relevant contract is awarded
Herbert Smith Freehills (Düsseldorf)
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Herbert Smith Freehills (Düsseldorf)
Facts of the case In December 2019, the Federal Cartel Office ("FCO") fined eleven technical building service providers approximately €110m for participation in a bid rigging cartel. The FCO’s investigation was initiated in November 2014 following a leniency application. According to the FCO, (...)

The Swedish Patent and Market Court of Appeal declines to grant leniency to a dairy company on the grounds that the information provided by the company was specifically requested by the Competition Authority and was not volunteered immediately (Arla Foods)
Swedish Competition Authority (Stockholm)
Arla Foods is not granted leniency in a case on unlawful cooperation* Arla Foods must pay an administrative fine for having been found guilty of unlawful cooperation in connection with a procurement. This is the decision in a judgment from the Patent and Market Court of Appeal. The Court (...)

The Hong Kong Competition Authority revises leniency programme for cartel conduct
Hong Kong Competition Commission (Hong Kong)
Competition Commission revises leniency programme for cartel conduct* The Competition Commission (Commission) today published a revised Leniency Policy for Individuals Involved in Cartel Conduct (Leniency Policy for Individuals) to offer clearer guidance and enhanced incentives for (...)

The Latvian Competition Authority fines three construction companies for an anticompetitive bid rigging cartel, with two fines reduced for cooperating with the Authority (PK Serviss / Koro Būve / Tavs Laikmets)
Latvian Competition Council (Riga)
The Competition Council fines three construction companies for prohibited agreements in procurement organized by a private contracting entity* On August 4, the Competition Council of Latvia (the CC) adopted a decision, detecting a prohibited agreement between three construction companies on (...)

The Austrian Competition Authority applies to the Cartel Court to review its ruling on a recent construction cartel following new evidence which may vitiate the award of leniency (STRABAG)
Austrian Competition Authority (Vienna)
Construction cartel: AFCA applies for review of STRABAG decision by Cartel Court* By decision of 21.10.2021 (27 Kt 12/21y), the Cartel Court imposed a fine of EUR 45.37 million on two companies of the STRABAG Group (STRABAG) for infringement of section 1 (1) of the Austrian Cartel Act (...)

The Hong Kong Competition Authority welcomes the Competition Tribunal’s judgement which orders price fixers in the travel industry to pay substantial fines, even after leniency reductions (Gray Line / Tak How / Wu)
Hong Kong Competition Commission (Hong Kong)
Competition Commission welcomes Tribunal’s orders on travel services sector price-fixing case* The Competition Commission (“Commission”) welcomes the orders granted by the Competition Tribunal (“Tribunal”) in proceedings concerning price-fixing in relation to the sales of tickets to tourist (...)

The Spanish Competition Authority extends the disciplinary proceedings for the manipulation and distribution of tenders related to military equipment (Comercial Hernando Moreno / Grupo de Ingeniería Reconstrucción y Recambios / Star Defence Logistics & Engineering / Casli)
Spanish Competition Authority (CNMC) (Madrid)
The CNMC extends the disciplinary proceedings for the manipulation and distribution of tenders related to military equipment* The initiation of proceedings is extended to a parent company and 6 executives. These proceedings investigate agreements and the distribution of tenders called in (...)

The Turkish Competition Authority issues first decision where leniency and settlement procedures are implemented together (Beypazarı İçecek Pazarlama Dağıtım Ambalaj Turizm Petrol İnşaat Sanayi ve Ticaret / Kınık Maden Suları)
Turkish Competition Authority (Ankara)
The First Decision where Leniency and Settlement Procedures are Implemented Together (25.5.2022) The investigation concerning Beypazarı İçecek Pazarlama Dağıtım Ambalaj Turizm Petrol İnşaat Sanayi ve Ticaret A.Ş. and Kınık Maden Suları A.Ş. was concluded. (26.5.2022)* The investigation (...)

The US DoJ updates its guidelines on leniency to include more generous terms for companies and individuals who cooperate
Morgan Lewis (Silicon Valley)
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Morgan Lewis (Chicago)
The US Department of Justice (DOJ) Antitrust Division announced significant guidance updates to its leniency program on April 4, 2022. Under the program, companies that self-report antitrust conspiratorial activity to the government (and then fully cooperate with the government in its (...)

The EU General Court dismisses appeals by 13 airlines against a readopted decision which imposed fines of €799M for price coordination (Airfreight cartel)
Van Bael & Bellis (Brussels)
On 30 March 2022, the General Court of the European Union (“General Court”) handed down thirteen separate judgments on appeals brought by airfreight carriers against the Commission’s re-adopted decision in the Airfreight case. Background In November 2010, the European Commission (...)

The Austrian Competition Authority files an action at the cartel court against a cabinet manufacturer for cartel activity (Cabinetmaking Cartel / Fürst)
Austrian Competition Authority (Vienna)
Joiner cartel: AFCA files another application with Cartel Court* In the course of its investigations into the joinery/cabinetmaking industry, the Austrian Federal Competition Authority (AFCA) filed an application with the Cartel Court on 28 March 2022 for a finding of an infringement (...)

The Spanish Competition Authority investigates possible anti-competitive practices in the food supply market to communities dependent on public bodies
Spanish Competition Authority (CNMC) (Madrid)
The CNMC investigates possible anti-competitive practices in the food supply market to communities dependent on public bodies* Such practices involve agreements for the tempering and allocation of tenders called in Spain. On 22 and 23 March, the CNMC carried out on-site inspections at the (...)

The Brazilian Competition Authority fines two companies and five individuals for anticompetitive conduct in the resin market (Royal Química / Cempre Apoio Educacional)
Brazilian Administrative Council for Economic Defense (CADE) (Brasilia)
Cartel in the resin market is fined 46.8 million reais* The authority convicted two companies and five individuals for the anticompetitive conduct On 23 March 2022, the Administrative Council for Economic Defense (CADE) convicted the firms Royal Química and Cempre Apoio Educacional, in (...)

The Spanish Competition Authority investigates several companies for the possible rigging of public tenders related to security and surveillance services
Spanish Competition Authority (CNMC) (Madrid)
The CNMC investigates several companies for the possible rigging of public tenders related to security and surveillance services* The possible agreements involving the rigging and allocation of tenders might have affected several public authorities. From March 1 to March 4, the CNMC carried (...)

The Finnish Competition Authority publishes updated guidelines on leniency for providing information on cartels
Finnish Competition and Consumer Authority (Helsinki)
The FCCA up­dated the guide­lines on im­mu­nity from penalty pay­ment and re­duc­ing the penalty pay­ment* The Finnish Competition and Consumer Authority (FCCA) has updated the guidelines on immunity from penalty payment and reducing the penalty payment in cartel cases. According to the (...)

The Swiss Competition Authority fines a German tobacco producer for a longstanding vertical distribution agreement which sought to secure absolute territorial protection (Pöschl)
Lenz & Staehelin (Zurich)
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Lenz & Staehelin (Zurich)
Competition Commission penalises German tobacco company for territorial restrictions in distribution agreements* The Competition Commission (ComCo) has once again imposed penalties on a foreign company for including/maintaining absolute territorial protection clauses in its distribution (...)

The Hong Kong Competition Authority commences proceedings against four undertakings and an individual for a price-fixing cartel in the travel services sector (Gray Line / Take How / Wu / Harbour Plaza 8 Degrees / Prudential Hotel)
Hong Kong Competition Commission (Hong Kong)
Competition Commission takes travel services sector price-fixing cartel case to Competition Tribunal* The Competition Commission (“Commission”) has today commenced proceedings in the Competition Tribunal (“Tribunal”) against four undertakings and one individual, namely: Gray Line Tours of (...)

The Canadian Competition Authority brings closure to a case against a Toronto construction company for bid rigging and collusion in the condo refurbishment market (CPL Interiors)
Journal of Parliamentary and Political Law (Ottawa)
Canada’s Competition Bureau (Bureau), which assists the Commissioner of Competition (Commissioner) in the administration and enforcement of the Competition Act (Act) , announced on 17 January 2022 that CPL Interiors Ltd. (CPL) was fined $761,967 (CAN) after pleading guilty for its role in a (...)

The Canadian Competition Authority fines a national construction company $761,967 after it pleaded guilty in a Toronto condo refurbishment bid-rigging scheme (CPL Interiors)
Canadian Competition Bureau (Gatineau)
CPL Interiors fined $761,967 after pleading guilty in GTA condo refurbishment bid-rigging scheme* Construction company CPL Interiors Ltd. was fined $761,967 today after pleading guilty before the Ontario Superior Court for its role in a criminal bid-rigging conspiracy. The bid-rigging scheme (...)

The Polish Competition Authority fines 6 truck dealers and 8 managers for concluding agreements that limit competition (Trucks Cartel)
Polish Competition Authority (Warsaw)
Truck dealer cartels - two decisions of the UOKiK President* UOKiK President Tomasz Chróstny issued two decisions concerning agreements limiting competition between truck dealers. Purchasers of these vehicles have not had a free choice of dealer for many years and have paid inflated prices. (...)

The Spanish Competition Authority opens disciplinary proceedings against several database marketing companies for customer-sharing and price-fixing agreements that could affect the marketing of business information products (Informa D&B / S.M.E / Compañía Española de Seguros de Crédito a la Exportación / Bureau Van Dijk Publicaciones Electrónicas / Moody’s Corporation)
Spanish Competition Authority (CNMC) (Madrid)
The CNMC opens disciplinary proceedings against several database marketing companies* It is investing potential customer-sharing and price-fixing (or discount) agreements relating to certain products. In June, the CNMC and the Autoridade da Concorrência (AdC) carried out on-site inspections (...)

The EU Commission fines multiple banks €344M for participating in a foreign exchange spot trading cartel (UBS / Barclays / RBS / HSBC / Credit Suisse)
European Commission - DG COMP (Brussels)
Antitrust: Commission fines UBS, Barclays, RBS, HSBC and Credit Suisse €344 million for participating in a Foreign Exchange spot trading cartel* The European Commission has completed its cartel investigation into the Foreign Exchange (‘Forex’) spot trading market by imposing fines on five (...)

The EU Commission fines an Italian canned food retailer €20 million for participating in a canned vegetable cartel (Conserve Italia)
European Commission - DG COMP (Brussels)
Antitrust: Commission fines Conserve Italia €20 million for participating in canned vegetables cartel* The European Commission has fined Conserve Italia Soc. coop. agricola and its subsidiary Conserves France S.A. (together ‘Conserve Italia’) a total of € 20 000 000 for breaching EU (...)

The Swedish Patent and Market Court rules that a company active in the cheese and dairy industry should pay an administrative fine for unlawful cooperation in dairy product procurement (Arla Foods)
Swedish Competition Authority (Stockholm)
Arla Foods to pay administrative fine for unlawful cooperation* The Patent and Market Court has in a judgment decided that Arla Foods is to pay an administrative fine for having participated in an unlawful cooperation ahead of a procurement. The fact that Arla Foods has cooperated with the (...)

The Hungarian Competition Authority imposes a fine on 3 companies active in the retail trade of agricultural machinery for sharing more than a dozen national public procurement procedures among themselves (Tempel Kereskedelmi és Szolgáltató / Normtec / Slovakian Premium Line)
Hungarian Competition Authority (Budapest)
The GVH imposed a fine on a public procurement cartel yet again* The Hungarian Competition Authority (GVH) imposed a fine of approximately HUF 135 million on three undertakings, which are active in the retail trade of agricultural machinery for sharing more than a dozen Hungarian public (...)

The German Competition Authority publishes new guidelines on its leniency program and the setting of fines in cartel proceedings
Herbert Smith Freehills (Düsseldorf)
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Herbert Smith Freehills (Düsseldorf)
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Herbert Smith Freehills (Brussels)
The German Federal Cartel Office (FCO) has published new guidelines on its leniency programme and on the setting of fines in cartel proceedings. Unfortunately, both guidelines are so far available only in German. The previous guidelines date from 2006 and 2013 respectively. The FCO has now (...)

The German Competition Authority publishes new guidelines on its leniency program and the setting of fines
German Competition Authority (Bonn)
Bundeskartellamt publishes new guidelines on its leniency programme and the setting of fines* The Bundeskartellamt has published new guidelines on its leniency program and on the setting of fines in cartel proceedings. Andreas Mundt, President of the Bundeskartellamt: “Key witnesses still (...)

The EU General Court dismisses five separate appeals in an electrolytic capacitors cartel case, including on increased fines for repeated offences and partial immunity from fines (NEC / Nichicon / Tokin / Rubycon / Nippon Chemi-Con)
Van Bael & Bellis (Brussels)
On 29 September 2021, the European General Court (“EGC”) dismissed in five separate judgments appeals lodged by Japanese producers, namely NEC Corporation, Nichicon Corporation, Tokin Corporation, Rubycon and Nippon Chemi-Con Corporation, against a decision adopted by the European Commission (...)

The New Zealand High Court fines a container company and its director for attempted collusion with a rival to charge consumers the same booking fee (SCS Christchurch)
New Zealand Commerce Commission (Wellington)
Penalties imposed in container depot price fixing case* The High Court has ordered Specialised Container Services (Christchurch) Limited (SCS Christchurch) and its director Grant Tregurtha to pay penalties in relation to an attempted price fix of “vehicle booking system” fees. The (...)

The New Zealand Competition Authority issues an anti-collusion reminder to businesses supplying essential services during the COVID-19 pandemic
New Zealand Commerce Commission (Wellington)
Commission issues anti-collusion reminder to businesses supplying essential services* The Commerce Commission is reminding all businesses supplying essential services in the current nationwide COVID-19 lockdown of their obligations under the Commerce Act. The Commission recognises that the (...)

The Brazilian Competition Authority recommends the conviction of cartel members in tenders of orthoses, prostheses, and medical devices (Biotronik Comercial Médica / Boston Scientific do Brasil / Medtronic Comercial / St. Jude Medical Brasil)
Brazilian Administrative Council for Economic Defense (CADE) (Brasilia)
CADE’s Office of the General Superintendent recommends the conviction of cartel members in tenders of orthoses, prostheses, and medical devices* Together, the collusive firms controlled the entire market of implantable cardiac pacemakers used in heart disease treatments On 24 August, CADE’s (...)

The EU Commission finds that three German car manufacturers colluded by deliberately limiting competition on innovation in greener technologies for diesel vehicles (BMW / Daimler / VW)
Municipality of Cagliari
By the cartel settlement decision recently rendered in Car Emissions, the European Commission (EC) found that three German car manufacturers colluded in the market for the reduction of emission of diesel cars during the period from June 2009 until October 2014. What is noteworthy in Car (...)

The EU Commission imposes a first-ever fine for collusion relating solely to technical development on three car manufacturers in the area of emission cleaning (BMW / Daimler / VW)
University of Vienna
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European Court of Justice (Luxembourg)
Uncharted legal territory? – European Commission fines Volkswagen and BMW for colluding on technical development in the area of emission cleaning* On 8 July 2021, the Commission found that Daimler, BMW and the Volkswagen Group (Volkswagen, Audi and Porsche) violated competition law by (...)

The Romanian Competition Authority opens an investigation into possible anti-competitive behavior of undertakings operating in the archiving services market (Enterprise Software Development / All Businesses Management / Cityplan Studio)
Romanian Competition Council (Bucharest)
The Competition Council carries out an investigation into the archiving services market* The Competition Council has opened an investigation on a possible anti-competitive behavior of some undertakings operating on the market of electronic / digital and physical archiving of documents, as (...)

The Brazilian Competition Authority convicts members of a cartel in procurements for PVC pipes and fittings (BR Plásticos Indústria / BRP Indústria Plástica / Nicoll Indústria Plástica Tigre / Amanco)
Brazilian Administrative Council for Economic Defense (CADE) (Brasilia)
CADE convicts a cartel in procurements for PVC pipes and fittings* In the hearing of this Wednesday (30 June), the Administrative Council for Economic Defense convicted five firms and six individuals for a cartel in public procurements for PVC pipes and fittings. Such procurements were aimed (...)

The Polish Competition Authority initiates a preliminary investigation into an alleged anticompetitive agreement by a car manufacturer and its dealers (Kia)
Polish Competition Authority (Warsaw)
Collusion by Kia car dealers? Preliminary investigation and searches by UOKiK* Are Kia cars sold in breach of competition law? President of the Office of Competition and Consumer Protection Tomasz Chróstny initiated a preliminary investigation into the matter, Office employees conducted (...)

The EU Commission imposes a fine of €371 million on banks implicated in supra-sovereign, sovereign and agency bond trading cartel (Bank of America / Natixis / RBS / UBS / UniCredit / WestLB)
Herbert Smith Freehills (Brussels)
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Herbert Smith Freehills (Brussels)
In April and May 2021 the European Commission ("EC") announced the imposition of fines totalling almost €400 million on banks implicated in two separate cartels relating to bond trading. In a separate development, the EC took unprecedented action to exclude a number of international banks from (...)

The EU Commission fines seven investment banks for operating a cartel in the primary and secondary markets for European government bonds (Bank of America / Natixis / RBS / UBS / UniCredit / WestLB)
Van Bael & Bellis (Brussels)
On 20 May 2021, the European Commission adopted a decision imposing fines on a series of investment banks relating to the trading of European Government Bonds (“EGB”). EGB In its decision, adopted on 20 May 2021, the Commission found seven investment banks, Bank of America, Natixis, (...)

The EU Commission fines investment banks €371M for participating in a European bonds trading cartel (Bank of America / Natixis / RBS / UBS / UniCredit / WestLB)
McDermott Will & Emery (Brussels)
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McDermott Will & Emery (Paris)
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McDermott Will & Emery (Paris)
By decision of 20 May 2021, the EC found that Bank of America, Natixis, Nomura, RBS (now NatWest), UBS, UniCredit and WestLB (now Portigon) breached EU antitrust rules through the participation of a group of traders in a cartel on the primary and secondary markets for European Government Bonds (...)

The EU Commission fines several investment banks €371M for participating in a European government bond trading cartel (Bank of America / Natixis / RBS / UBS / UniCredit / WestLB)
European Commission - DG COMP (Brussels)
Antitrust: Commission fines investment banks € 371 million for participating in a European Governments Bonds trading cartel* The European Commission has found that Bank of America, Natixis, Nomura, RBS (now NatWest), UBS, UniCredit and WestLB (now Portigon) have breached EU antitrust rules (...)

The Czech Competition Authority fines two national infrastructure companies for public procurement cartel (SPIE Elektrovod / ASE)
Czech Competition Authority (Brno)
SPIE ELEKTROVOD and ASE were fined almost CZK 34 million for public procurement cartel* In its first instance decision, the Office for the Protection of Competition imposed fines in the total amount of CZK 33,917,000 on SPIE Elektrovod, a.s. and ASE, s.r.o. for a cartel agreement concerning (...)

The Polish Competition Authority fines an online office equipment retailer for resale price maintenance (Fellowes)
Polish Competition Authority (Warsaw)
Collusion on office equipment market - decision of the President of UOKiK* Collusion on office equipment market - decision of the President of UOKiK Fellowes Poland for many years imposed minimum prices on distributors for resale of office equipment on the Internet. Tomasz Chróstny, President (...)

The EU Commission imposes a fine of €28.5 million on banks implicated in European government bond trading cartel (Bank of America Merrill Lynch / Crédit Agricole / Crédit Suisse)
Herbert Smith Freehills (Brussels)
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Herbert Smith Freehills (Brussels)
In April and May 2021 the European Commission ("EC") announced the imposition of fines totalling almost €400 million on banks implicated in two separate cartels relating to bond trading. In a separate development, the EC took unprecedented action to exclude a number of international banks from (...)

The EU Commission imposes total fines of €28 million on three investment banks for their involvement in a cartel in the EEA secondary trading market for SSA bonds denominated in US Dollars (Bank of America Merrill Lynch / Crédit Agricole / Crédit Suisse)
Van Bael & Bellis (Brussels)
On 28 April, the European Commission adopted a decision imposing fines on a series of investment banks relating to the trading of Supra-sovereign, Sovereign and Agency (“SSA”) bonds. SSA Bonds In the first decision, adopted on 28 April 2021, the Commission imposed total fines of € 28 (...)

The French Competition Authority fines three sandwich makers for creating a cartel (Roland Monterrat / La Toque Angevine / Daunat)
Vaillant Group (Paris)
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Huawei Technologies (Boulogne-Billancourt)
The French Competition Authority (“FCA”) recently fined the three main French manufacturers of sandwiches for mass retail distribution for having implemented a volume and customer allocation plan over a six-year period and agreed on the price level to be offered to their customers (€24.5 (...)

The French Competition Authority fines the three main national manufacturers of industrial sandwiches sold under a private label for having defined a common strategy when responding to calls for tender launched by large and medium-sized retailers (Roland Monterrat / La Toque Angevine / Daunat)
Herbert Smith Freehills (Paris)
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Baudelin Avocat (Paris)
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Herbert Smith Freehills (Brussels)
On 24 March 2021, the FCA fined the three main French manufacturers of industrial sandwiches sold under private label for having defined a common strategy when responding to calls for tender launched by large and medium-sized retailers. The FCA launched dawn raids at the premises of the (...)

The French Competition Authority fines three industrial sandwich manufacturers €24.5M for an anticompetitive agreement (Roland Monterrat / La Toque Angevine / Daunat)
Autorité de la concurrence (Paris)
The Autorité de la concurrence fines the three main French manufacturers of industrial sandwiches sold under retailer’s own brand label for anticompetitive agreement* Background The Autorité de la concurrence fines Roland Monterrat, La Toque Angevine (hereinafter "LTA") and Snacking Services (...)

The EU Court of Justice reduces the fine imposed on a company in the steel abrasives cartel case (Pometon)
Van Bael & Bellis (Brussels)
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Van Bael & Bellis (Brussels)
On 18 March 2021, the European Court of Justice (“ECJ”) delivered its judgment in Pometon SpA v European Commission (Case C-440/19) in connection with the Steel Abrasives cartel case. In its judgment, the ECJ partially upheld the appeal in so far as it found that the General Court had breached (...)

The Finnish Market Court finds that three manufacturers of expanded polystyrene engaged in a single and continuous national price-fixing cartel (Jackon Finland / UK-Muovi / Styroplast)
Hannes Snellman (Helsinki)
On 3 March 2021, the Market Court agreed with the submission of the Finnish Competition and Consumer Authority ("FCCA"), that three manufacturers of expanded polystyrene (“EPS”), a building insulation material, had engaged in a national price fixing cartel lasting one and a half years. One (...)

The Polish Competition Authority fines two animal feed manufacturers for collusion (Polmass / Agro-Netzwerk Polska)
Polish Competition Authority (Warsaw)
Collusion between animal feed manufacturers - decision of the President of UOKiK* President of UOKiK Tomasz Chróstny proclaimed market allocation by animal feed producers - collusion limited the freedom of product choice for farmers and sellers of milk replacers. Polmass company was (...)

The German Competition Authority fines three steel forging companies for exchanging information (Bharat Forge Global / Musashi Bockenau / Bad Sobernheim)
German Competition Authority (Bonn)
Bundeskartellamt imposes fines on steel forging companies* The Bundeskartellamt has imposed fines totalling approx. 35 million euros on three steel forging companies and two senior staff members for their involvement in an anti-competitive exchange of information. The companies concerned are (...)

The Czech Competition Authority sanctions a bid-rigging agreement on projecting high-speed rails (Sudop / VUZ)
Bird & Bird (Prague)
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Dentons (Prague)
Leniency programmes and settlement procedures are commonly used by the Czech Office for the Protection of Competition (“Office”). The leniency programme was used as a “soft law” by the Office since 2001 to promote discovery of unlawful horizontal agreements. As for the settlement procedure, it (...)

The Czech Competition Authority fines a national transport company for participating in a cartel revealed by the leniency programme (Sudop / VUZ)
Czech Competition Authority (Brno)
Railway design cartel revealed thanks to leniency programme, the office imposed fine on sudop praha* By its first-instance decision, the Office for the Protection of Competition punished bid rigging agreement on projecting high-speed rails concluded by SUDOP PRAHA a. s. (hereinafter referred (...)

The Romanian Competition Authority fines a national association and 16 financial companies €8.47 million for exchanging information (Association of Romanian Financial Companies)
Romanian Competition Council (Bucharest)
The Competition Council has fined the Romanian Association of Financial Companies and 16 financial companies euro 8.47 million* The Competition Council has fined the Association of Romanian Financial Companies (hereinafter ALB) and 16 member companies lei 41,251,774 (approx. Euro 8.47 (...)

The Polish Competition Authority fines several fitness chains for collusion (Benefit Systems / Bartosz Gibała / Platinium Wellness)
Polish Competition Authority (Warsaw)
Collusion on the fitness market - decision by the President of UOKiK* Tomasz Chróstny, the President of UOKiK, has imposed over PLN 32 million in financial penalties on the largest fitness chains, including Benefit Systems (operator of MultiSport cards) for a competition-restricting collusion (...)

The UK Competition Authority fines suppliers of groundworks products to the construction industry for coordinating their commercial activities (Vp / M.G.F.)
Ashurst (London)
On 17 December 2020, the CMA issued a decision finding that three UK-based suppliers of groundworks products to the UK construction industry had illegally colluded in order to reduce competition and maintain or increase prices, in breach of Chapter 1 of the Competition Act 1998 and Article 101 (...)

The UK Competition Authority fines construction suppliers £15M for collusion (Vp / M.G.F.)
UK Competition & Markets Authority - CMA (London)
Construction suppliers fined £15m for breaking competition law* The CMA has fined 2 major suppliers to the construction industry more than £15m for illegally colluding to reduce competition and keep prices up Following an investigation by the Competition and Markets Authority (CMA), 2 (...)

The Turkish Competition Authority fines auto expertise services providers for price fixing and supply cartel (Auto / Çözüm / Dyno Max...)
ACTECON (Istanbul)
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ACTECON (Istanbul)
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ACTECON (Istanbul)
On 17 December 2020, the Turkish Competition Authority (“TCA”) announced, on its website, the reasoned decision as a result of its investigation against certain auto expertise services providers in a province of Turkey (i.e. Gaziantep), unveiling a price fixing and supply cartel among the (...)

The UK Competition Authority fines two groundworks suppliers for cartel activity (Vp / M.G.F.)
Government Legal Department (London)
On 17 December 2020, the UK’s Competition and Markets Authority (“CMA”) issued an infringement decision fining two companies which supply groundworks products Vp plc and M.G.F. (Trench Construction Systems) Ltd more than £ 11.2 million and £ 3.7 million, respectively, for illegal collusion. (...)

The US DOJ indicts a former owner of a North Texas physical therapist staffing company for conspiring with competitors to suppress wages (Neeraj Jindal)
US Department of Justice (Washington)
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WilmerHale (Washington)
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Axinn Veltrop & Harkrider (Washington)
This article has been nominated for the 2021 Antitrust Writing Awards. Click here to learn more about the Antitrust Writing Awards. On Dec. 10, the U.S. Department of Justice Antitrust Division announced in U.S. v. Jindal the criminal indictment of a former owner of a North Texas physical (...)

The German Regional Court of Bonn dismisses a pesticide producer’s claim for state liability against the Competition Authority (BayWa)
Van Bael & Bellis (Brussels)
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Van Bael & Bellis (Brussels)
On 2 December 2020, the Regional Court of Bonn (“Court”) dismissed a claim of € 72.8 million by crop protection producer BayWa against the German Federal Cartel Office (“FCO”). BayWa argued that the FCO had violated its procedural rights, in particular the principle of equal treatment, in the (...)

The Slovak Competition Authority fines three undertakings for a cartel agreement in the area of supplies of machines and mechanical and technological equipment
Slovak Competition Authority (Bratislava)
AMO SR decided to impose fines on three undertakings for a cartel agreement in the area of supplies of machines and mechanical and technological equipment* On 18 November 2020 the Antimonopoly Office of the Slovak Republic, the Division of Cartels, (hereafter "the Office") issued a decision, (...)

The Luxembourg Competition Authority imposes its highest ever fine of €3.3M for retail price maintenance practices (Bahlsen / Auchan / Cactus / Delhaize)
Arendt & Medernach (Luxembourg)
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Cleary Gottlieb Steen & Hamilton (Brussels)
I. Introduction On 18 November 2020, at the end of an eventful 2020, the Luxembourg Competition Council announced the adoption of “the most important decision that the authority has ever taken, in terms of content and the amount of the penalty”. Indeed, the imposition of an aggregate fine (...)

The Luxembourg Competition Authority fines food company and 3 supermarkets €3.3 million for resale price maintenance (Bahlsen / Auchan / Cactus / Delhaize)
Luxembourg Competition Council (Liège)
The Luxembourg Competition Council fines Bahlsen and the supermarkets Auchan, Cactus and Delhaize of €3.3 million* In three decisions dated 18 November 2020, the Competition Council fines Bahlsen and the supermarkets Auchan, Cactus and Delhaize of €3.3 million for resale price maintenance (...)

The Polish Competition Authority fines a music manufacturer for setting minimum online resale prices (Yamaha Music Europe)
Van Bael & Bellis (Brussels)
According to a press release of 5 November 2020, the Polish Office of Competition and Consumer Protection (the “UOKIK”) imposed a fine of PLN 511,806.92 (approximately € 114,000) on musical equipment manufacturer Yamaha for setting minimum prices at which its products could be sold by (...)

The UK Competition Authority fines two suppliers of rolled lead £9.5M for entering into anticompetitive arrangements (Associated Lead Mills / BLM British Lead)
Government Legal Department (London)
On 4 November 2020, the UK’s Competition and Markets Authority (“CMA”) imposed fines totalling £9.5 million on two of the UK’s largest rolled lead suppliers for their role in a roofing lead cartel. The CMA fined Associated Lead Mills Ltd and H.J. Enthoven Ltd (trading as BLM British Lead) £1.5 (...)

The UK Competition Authority issues fines of over £9 million for roofing lead cartel (Associated Lead Mills / BLM British Lead)
UK Competition & Markets Authority - CMA (London)
CMA issues fines of over £9m for roofing lead cartel* The CMA has imposed fines totalling more than £9m on 2 of the UK’s largest suppliers of rolled lead, for breaking competition law. Following an investigation into suspected cartel conduct, the Competition and Markets Authority (CMA) (...)

The Hong Kong Competition Authority welcomes the Competition Tribunal’s judgment against an IT cartel for price-fixing in the first case where the liability and relief portions of the proceedings have been resolved by settlement (Quantr / Cheung Man Kit / Nintex)
Hong Kong Competition Commission (Hong Kong)
Competition Commission welcomes judgment in IT cartel conduct case* The Competition Commission (Commission) welcomes the judgment handed down by the Competition Tribunal (Tribunal) today (3 November) in proceedings involving the exchange of competitively sensitive information in the IT (...)

The US DoJ applauds the US President’s authorization of The Antitrust Criminal Penalty Enhancement And Reform Permanent Extension Act
US Department of Justice (Washington)
Department Of Justice Applauds President Trump’s Authorization Of The Antitrust Criminal Penalty Enhancement And Reform Permanent Extension Act* On October 1, President Donald J. Trump signed into law a continuing resolution that contains the Antitrust Criminal Penalty Enhancement and Reform (...)

The Romanian Competition Authority sanctions 5 companies with €468,000 for rigging the bids on rehabilitation of the streets in Pitesti (Construct Steel Market / Construcții Drumuri și Lucrări de Artă / Comesad Drumuri / General Trust Argeș / Selca)
Romanian Competition Council (Bucharest)
The Competition Council Sanctioned Five Companies With Lei 2.23 Million for Riging the Bid* The Competition Council sanctioned with fines amounting 2,237,094 lei (approx. 468,000 euro) five companies for rigging the bids on rehabilitation of the streets in Pitesti, as follows: Construct (...)

The EU Commission fines car parts suppliers €18 million in cartel settlement in the market for closure systems for cars (Brose / Kiekert / Magna)
European Commission - DG COMP (Brussels)
Antitrust: Commission fines car parts suppliers of € 18 million in cartel settlement* The European Commission has fined Brose and Kiekert a total of € 18 million for taking part in two cartels concerning supplies of closure systems for cars in the European Economic Area (EEA). Magna was not (...)

The Romanian Competition Authority fines five companies € 468,000 for participating in a bid rigging cartel in public tender for street refurbishment (Construct Steel Market / Construcții Drumuri și Lucrări de Artă / Comesad Drumuri / General Trust Argeș / Selca)
Van Bael & Bellis (Brussels)
On 24 September 2020, the Romanian Competition Council (“RCC”) imposed fines totalling € 468,000 on five companies for engaging in bid-rigging in relation to public tenders concerning the refurbishment of certain streets in the Romanian city of Pitesti. The investigation started in 2018 (...)

The Austrian Cartel Court finds a musical instruments maker to have engaged in resale price maintenance (Roland Germany)
Van Bael & Bellis (Brussels)
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Clifford Chance (Brussels)
According to a press release issued by the Austrian Federal Competition Authority (“FCA”), the Austrian Cartel Court ruled on 24 September 2020 that musical instruments maker Roland Germany GmbH (“Roland Germany”) had violated the competition rules by entering into agreements fixing minimum (...)

The Austrian Cartel Court finds musical instrument manufacturer guilty of price fixing (Roland Germany)
Austrian Competition Authority (Vienna)
Cartel Court finds Roland Germany GmbH guilty of price fixing* The company cooperated with the AFCA within the leniency programme On 24 September 2020 the Cartel Court, acting on the Austrian Federal Competition Authority’s (AFCA) application of 2 June 2020, found Roland Germany GmbH to (...)

The Spanish Competition Authority fines 33 school transport companies and one association for creating a school transport cartel (School transport cartel / Asociación Navarra de Empresarios del Transporte por Carretera y Logística)
Spanish Competition Authority (CNMC) (Madrid)
The CNMC fines 33 school transport companies and one association for creating a school transport cartel in Navarre* The companies conspired to share the school transport by zones and deceive the School Board of the Government of Navarre, driving up the prices of the service for 8 years. The (...)

The Spanish Competition Authority fines 33 school transport companies and one association with €3.36 million for creating a school transport cartel (School transport cartel / Asociación Navarra de Empresarios del Transporte por Carretera y Logística)
Van Bael & Bellis (Brussels)
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Van Bael & Bellis (Brussels)
On 9 September 2020, the Spanish Competition Authority (“CNMC”) imposed fines totalling € 3.36 million on 33 school transport companies and fined one association € 15,000 for their involvement in a bid-rigging cartel in the school transport sector in the region of Navarre from 1 December 2013 (...)

The Russian Competition Authority announces they prevented the creation of a cartel in the pharmaceutical market (Danta / Company Organika)
Russian Federal Antimonopoly Service (Moscow)
Rostov OFAS prevented pharmaceutical cartel with an income of more than 120 million rub* Illegal income of Danta LLC and Company Organika LLC was obtained by colluding at 48 auctions for the supply of medicines Rostov OFAS found that auctions where Danta LLC and Company Organika LLC (...)

The Polish Competition Authority imposes penalties on producers of feed for breeding animals for engaging in market sharing and concluding restricting agreements (Polmass / Ekoplon)
Polish Competition Authority (Warsaw)
President of UOKiK has imposed penalties of more than PLN 17 million for market division scheme* Producers of feed for breeding animals – Polmass and Ekoplon – have concluded competition-restricting agreements. They shared two markets, thus limiting customers in their free selection of (...)

The Dutch Trade and Industry Appeals Tribunal reduces by 99% a fine which was imposed by the Competition Authority for a cartel due to the special circumstances surrounding the COVID-19 pandemic
Netherlands Authority for Consumers & Markets- ACM (The Hague)
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Bird & Bird (The Hague)
The Dutch Trade and Industry Appeals Tribunal (College van Beroep voor het bedrijfsleven, “CBb”) reduced a fine imposed by the Dutch Authority for Consumers & Markets (“ACM”) on an unidentified undertaking with 99%, from €1 million to €10.000,-. The ACM asked the court to lower the fine, (...)

The UK Competition Authority consults on amending guidance on applications for leniency and no-action in cartel cases
Cleary Gottlieb Steen & Hamilton (London)
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Cleary Gottlieb Steen & Hamilton (London)
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Cleary Gottlieb Steen & Hamilton (Brussels)
The CMA’s Guidance on applications for leniency and no-action in cartel cases provides detailed guidance on the principles and process for leniency applications. On 30 July 2020, the CMA invited comments on a proposed addendum to clarify the way the CMA will exercise its discretion in relation (...)

The Polish Competition Authority publishes guidelines on sanctions for companies and their managers for implementing anticompetitive agreements
Bird & Bird (Warsaw)
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Bird & Bird (Warsaw)
The Polish Competition and Consumer Protection Act foresees that sanctions for implementing anticompetitive agreements may be imposed on companies and their managers. In fact, managers who have intentionally permitted their company to engage in such practices can face a fine of up to PLN 2 (...)

The Indian Government allows the Tax Department to share information with the Competition Authority, which proceeded to give leniency to the two companies involved in cartel cases in the transport sector during the COVID-19 pandemic (Automotive Bearing / Railway Locomotive)
IndusLaw (Delhi)
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AZB & Partners (Mumbai)
CCI joins forces with the Indian Tax Department: A new dawn for the Indian Fair-trade regulator?* The outbreak of the Covid-19 pandemic has worsened the already struggling Indian economy and the sky-high growth in the cartel cases in the country comes as no surprise. However, given the (...)

The Hellenic Competition Authority fines two furniture companies for bid-rigging a public hospital’s tender but reduces their fines for cooperation in the case (Papanastasiou / Pichas)
Hellenic Competition Commission (Athens)
Decision on the ex-officio investigation in the furniture and professional equipment market (703/2020)* The Hellenic Competition Commission (HCC), in plenary, adopted a unanimous decision following the simplified Settlement Procedure according to article 25a of Law 3959/2011 and Decision no. (...)

The French Competition Authority fines 12 manufacturers for cartel in the ham and cold meat sector (Charcuterie cartel)
Autorité de la concurrence (Paris)
The Autorité hands out fines worth 93 million euros to a cartel in the ham and cold meats (charcuterie) sector* The manufactures involved (“cold meat manufacturers”) worked in concert in order to purchase cuts of ham from slaughterhouses at lower prices and/or were fixing the price (...)

The EU Commission fines ethylene purchasers €260 million in a cartel settlement (Orbia / Clariant / Calanese / Westlake)
Van Bael & Bellis (Brussels)
On 14 July 2020, the European Commission (the “Commission”) announced that it had adopted a decision fin‐ ing three ethylene purchasers a total of € 260,443,000. The companies concerned namely, Orbia (Mexico), Clari‐ ant (Switzerland), Calanese (United States) and Westlake (United States), (...)

The EU Commission fines ethylene purchasers for having colluded and exchanged information on purchase prices (Orbia / Clariant / Celanese / Westlake)
Ashurst (Brussels)
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ADNOC Group (Abu Dhabi)
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Ashurst (London)
Fines for ethylene purchasing cartel On 14 July 2020, the European Commission ("Commission") fined ethylene purchasers Orbia, Clariant and Celanese EUR 260 million for having colluded and exchanged information on purchase prices on the ethylene merchant market with a fourth participant, (...)

The EU Commission fines ethylene purchasers €260 million in cartel settlement for colluding to buy at the lowest possible price (Orbia / Clariant / Celanese / Westlake)
European Commission - DG COMP (Brussels)
Antitrust: Commission fines ethylene purchasers € 260 million in cartel settlement* The European Commission has fined Orbia, Clariant and Celanese a total of € 260 million for breaching EU antitrust rules. Westlake was not fined as it revealed the cartel to the Commission. The companies (...)

The EU Commission fines ethylene purchasers in the chemical industry for participating in a cartel aimed at purchasing a product at the lowest possible price (Orbia / Clariant / Celanese / Westlake)
Herbert Smith Freehills (Brussels)
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Herbert Smith Freehills (Brussels)
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Herbert Smith Freehills (Brussels)
On 22 January 2021, the European Commission published a non-confidential version of its decision to fine ethylene purchasers Orbia, Clariant and Celanese a total of EUR 260 million for participating in a cartel aimed at purchasing ethylene at the lowest possible price, to the detriment of (...)

The US DoJ applauds the International Competition Network’s new international leniency guidelines
US Department of Justice (Washington)
Antitrust Division Applauds New International Leniency Guidelines* New guidelines will increase effectiveness of international cartel enforcement through better cooperation The Antitrust Division helped lead the International Competition Network (ICN) initiative on cross-border leniency (...)

The EU General Court reduces the fine imposed on a company for its participation in the smart card chip market by almost €6 million (Infineon Technologies)
Callol, Coca & Asociados (Madrid)
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Callol, Coca & Asociados (Madrid)
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Callol, Coca & Asociados (Madrid)
By decision of 3 September 2014, the Commission established the existence of a cartel in the smart card chip sector in the EEA from 2003 to 2005. Within said cartel, several undertakings, namely Infineon, Philips, Samsung and Renesas, had coordinated their pricing policy through a network of (...)

The Czech Competition Authority imposes fines for illegal cartel agreement in the rail freight transport market (AWT / Interfracht / Argo Logistics / Spedica)
Bird & Bird (Prague)
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Dentons (Prague)
On 22 June 2020 the Czech Office for the Protection of Competition (Office) published a press release (without publishing the full decision yet) regarding fines imposed for concluding and executing a prohibited cartel agreement regarding train projects Carpathia, Sylvania, and New Carpathia. (...)

The OECD holds a roundtable on the criminalisation of cartels and bid-rigging conspiracies
OECD - Competition Division (Paris)
Sanctions against cartels vary greatly across jurisdictions, from monetary fines against firms and other legal persons, to criminal sanctions (including custodial sentences) against individuals. In the last years, an increased adoption of criminal enforcement regimes has been observed across (...)

The Indian Competition Authority finds four automotive and industrial bearing companies liable for price-fixing and issues a cease and desist against collusive behaviour (Schaeffler / SKF / NEI / Tata)
Trilegal (Mumbai)
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Trilegal (Mumbai)
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Karkinos Healthcare (Mumbai)
The Competition Commission of India (CCI) recently found National Engineering Industries Ltd. (NEI), Schaeffler India Ltd. (Schaeffler), SKF India Ltd. (SKF) and Tata Steel Ltd., Bearing Division (Tata) (collectively, OPs) to have collusively fixed the prices of automotive and industrial (...)

The Indian Competition Authority issues two cease and desist orders in recent leniency decisions concerning railway companies and four industrial and automotive bearings manufacturers but avoids fining due to companies’ size and the economic impact of COVID-19 (Schaeffler / SKF / NEI / Tata) (Chief Materials Manager, South Eastern Railway / Hindustan Composites)
Khaitan & Co (Mumbai)
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Khaitan & Co (New Delhi)
This article has been nominated for the 2021 Antitrust Writing Awards. Click here to learn more about the Antitrust Writing Awards. Two recent cartel findings in quick succession, yet no penalties in either. Strange as it may seem, it is true. We speak of the Competition Commission of India (...)

The Indian Competition Authority issues for the first time in a cartelization case a cease and desist order with no penalty against 4 industrial and automotive bearings manufacturers (Schaeffler / SKF / NEI / Tata)
Lakshmikumaran & Sridharan (New Delhi)
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Lakshmikumaran & Sridharan (New Delhi)
Two of the final orders recently pronounced by the CCI finding parties in violation of the cartel and bid-rigging provisions of the Competition Act, 2002 (“Act”) have come as a surprise to many. While the CCI found clinching evidence regarding the existence of an agreement to cartelize and rig (...)

The Spanish Supreme Court sheds light on the liability of cartel members not directly active in the relevant market (FENIN)
Callol, Coca & Asociados (Madrid)
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Callol, Coca & Asociados (Madrid)
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Latham & Watkins (Brussels)
In 2016, the CNMC fined €128.8 million on seven manufacturers, a business association (the Spanish Federation of Healthcare Technology Companies (FENIN)) and four individuals for setting up a price-fixing cartel of adult diapers sold in pharmacies (Decision of 26 May 2016, AIO, file (...)

The Austrian Supreme Cartel Court requests preliminary ruling from the EU Court of Justice concerning territorial agreements in connection with the sale of industrial sugar (Zuckerkartell)
Austrian Competition Authority (Vienna)
Supreme Cartel Court submits questions to European Court of Justice in the appeals procedure concerning territorial agreements in connection with the sale of industrial sugar* In the cartel case on territorial agreements in connection with the sale of industrial sugar, Vienna Higher Regional (...)

The German Competition Authority finalises fines totalling €110 million on eleven providers of technical building services for collusion in the award of major contracts (Caverion / Elektrotherm / Landshut / Engie / Cologne / Ferrostaal Air Technolgy / Saarwellingen / Stuttgart...)
Bird & Bird (Dusseldorf)
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Bird & Bird (Dusseldorf)
In December 2019 the Federal Cartel Office (“FCO”) imposed fines totalling EUR 110 million on eleven providers of technical building services for collusion in the award of major contracts. The proceedings were initiated in November 2014 following a leniency application. The leniency (...)

The German Competition Authority fines technical building service providers for bid-rigging (Caverion Deutschland)
German Competition Authority (Bonn)
Bundeskartellamt / Cartel prosecution* Bundeskartellamt finalized fines proceedings against providers of technical building services Bonn, 27 March 2020: In December 2019 the Bundeskartellamt has finalised the fines proceedings against eleven technical building service providers. The (...)

The Mexican Competition Authority issues its new regulatory provisions of the leniency and immunity program
Mexican Competition Authority (Mexico City)
COFECE issues Regulatory Provisions of the Leniency and Immunity Program* The Regulatory Provisions are legally binding and aimed at providing tat providing greater legal certainty on procedures related to the Leniency and Immunity Program Mexico City, March 4, 2020.- The Mexican Federal (...)

The Polish Competition Authority imposes a €325,000 fine on an office equipment maker for engaging in online retail price maintenance (Brother)
Van Bael & Bellis (Brussels)
On 11 February 2020, the Polish Office of Competition and Consumer Protection (the “UOKIK”) imposed a fine of PLN 1.4 million (approximately € 325,000) on office equipment maker Brother for online retail price maintenance (“RPM”). The UOKIK’s decision explains that, between the years 2010 (...)

The Polish Competition Authority imposes a fine on a manufacturer of office equipment who set minimum online sale prices for its printers (Brother)
Bird & Bird (Warsaw)
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Bird & Bird (Warsaw)
In February 2020, the Polish Competition Authority (“UOKiK”) announced that in December 2019 it imposed a PLN 1.4 million fine on Brother Central & Eastern Europe (“Brother”), a manufacturer of office equipment, which set minimum online sale prices for printers. Between 2010 and 2017, (...)

The German Competition Authority imposes fines totalling €154.6M on pesticide suppliers for agreeing on price lists, rebates and retail prices (Agravis / Agro Agrargroßhandel / BayWa / BSL Betriebsmittel Service Logistik / Getreide / Raiffeisen Waren / ZG Raiffeisen)
Van Bael & Bellis (Brussels)
On 13 January 2020, the German Federal Cartel Office (FCO) imposed fines totalling € 154.6 million on seven undertakings for agreeing on price lists, rebates and retail prices for plant protection products between 1998 and 2015. Fines were also imposed on employees implicated in the infringing (...)

The German Competition Authority fines seven wholesalers of plant protection products and their responsible employees for agreeing on price lists, discounts and some individual sales prices (Agravis / Agro Agrargroßhandel / BayWa / BSL Betriebsmittel Service Logistik / Getreide / Raiffeisen Waren / ZG Raiffeisen)
German Competition Authority (Bonn)
Wholesalers of plant protection products fined for anti-competitive agreements on price lists, discounts and individual prices* Bonn, 13 January 2020: The Bundeskartellamt has imposed fines totalling 154.6 million euros on seven wholesalers of plant protection products and their responsible (...)

The Hungarian Competition Authority fines undertakings €4.8 million for sharing EU-funded public procurement tenders for diagnostic imaging equipment (GE Hungary / Premier G / Euromedic Technology)
Bird & Bird (Budapest)
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Bird & Bird (Budapest)
The Hungarian Competition Authority (’’GVH’’) fined several undertakings which were found to have shared amongst themselves the EU-funded public procurement tenders for diagnostic imaging (MRI, CT and X-ray) equipment in Hungary in 2015. The total fine amounts to EUR 4.8 million, with GE (...)

The Dutch Competition Authority assists the French Competition Authority with dawn raids of a cartel in the apple sauce market (Coroos)
Netherlands Authority for Consumers & Markets- ACM (The Hague)
ACM AND THE FRENCH COMPETITION AUTHORITY HAVE WORKED TOGETHER IN FINING A FRENCH CARTEL* The French competition authority today imposed fines, totalling 58.3 million euros, on seven food companies for concluding anticompetitive arrangements regarding the selling of apple sauce. These (...)

The French Competition Authority fines fruit-compote manufacturers for pricing agreement and market sharing (Conserves France / Valade / Délis / Vergers de Chateaubourg / Materne / Andros / Charles Faraud / Charles & Alice)
Autorité de la concurrence (Paris)
The Autorité de la concurrence hands down fine worth a total of up to 58.3 million euros to the main fruit-compote manufacturers for pricing agreement and market sharing* Background The Autorité publishes today a decision by which it fines a national cartel between the main fruit-compote (...)

The German Competition Authority fines three companies and three people €646 million for agreeing and exchanging certain supplements and surcharges for quarto plates (Ilsenburger / Thyssenkrupp Steel / Voestalpine)
Tesa (Hamburg)
Steel manufacturers fined record €646 million for agreeing surcharges and exchanging information* The Federal Cartel Office (FCO) has fined three companies and three persons a total of approximately €646 million. The companies agreed and exchanged certain supplements and surcharges for (...)

The UK Ofcom finds an illegal market-sharing agreement in the parcel delivery services (Royal Mail / The SaleGroup)
Ashurst (London)
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Ashurst (London)
On 14 November 2019, Ofcom issued an infringement decision under Article 101 TFEU and Chapter 1 Competition Act 1998 against Royal Mail and The SaleGroup Limited ("TSG") finding that a parcel delivery services agreement was anticompetitive. This was swiftly followed by a decision to open a (...)

The Hellenic Competition Authority signs a protocol on cooperation with the Single Public Procurement Authority
University of Portsmouth
PROTOCOL ON COOPERATION BETWEEN THE GREEK COMPETITION AUTHORITY AND THE GREEK PUBLIC PROCUREMENT AUTHORITY* In October 2019, the Hellenic Competition Commission signed Protocol on Cooperation with the Hellenic Single Public Procurement Authority. Both agencies have agreed on the areas of (...)

The Spanish Competition Authority fines companies for participating in a cartel in the industrial assembly and maintenance sector (Montaje Y Mantenimiento Industrial)
European Commission - DG COMP (Brussels)
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Gómez-Acebo & Pombo (Brussels)
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Basic-Fit (Hoofddorp)
The CNMC has dismantled a cartel in the industrial assembly and maintenance sector. According to the CNMC, the practices in question were conducted with the aim of increasing prices in the services provided, mainly, to energy and petrochemical clients. The cartel members engaged in client (...)

The Australian Competition Authority starts applying an updated cartel immunity policy which requires a higher level of cooperation for leniency and introduces a new online portal for whistleblowers
King & Wood Mallesons (Sydney)
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King & Wood Mallesons (Sydney)
This article has been nominated for the 2020 Antitrust Writing Awards. Click here to learn more about the Antitrust Writing Awards. From 1 October 2019, the Australian Competition and Consumer Commission (ACCC) will apply an updated cartel immunity and cooperation policy, with the changes (...)

The Serbian Competition Authority issues its first decision granting immunity from a fine of €500K to a cartel participant based on a leniency application (Konica Minolta distributors)
Schoenherr (Belgrade)
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Schoenherr (Belgrade)
Almost 10 years after the introduction of the leniency programme in Serbia, the Commission for Protection of Competition (’Commission’) adopted on 27 of September 2019 the first decision granting immunity from a fine to a cartel participant. This decision brings to life the 2009 statutory (...)

The EU Commission fines two manufacturers of processed vegetables €31.65 million for participating in a canned vegetable cartel and grants full immunity to a third participant for blowing the whistle (Coroos / CECAB)
Addleshaw Goddard (Paris)
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ADNOC Group (Abu Dhabi)
On 27 September 2019, the European Commission ("Commission") fined Coroos and Groupe CECAB €31.65 million for participating in a canned vegetables cartel for over 13 years, with a third participant, Bonduelle, receiving full immunity for blowing the whistle. WHAT YOU NEED TO KNOW - KEY (...)

The EU Commission imposes fines totaling €31.6M on two companies for participating in a cartel in the canned vegetable sector (Coroos / CECAB)
European Commission - DG COMP (Brussels)
Antitrust: Commission fines Coroos and Groupe CECAB €31.6 million for participating in canned vegetables cartel* The European Commission has fined Coroos and Groupe CECAB a total of € 31 647 000 for breaching EU antitrust rules. Bonduelle was not fined as it revealed the existence of the (...)

The Swiss Competition Authority fines a manufacturer of sports products for vertical price fixing with dealers (Stöckli)
Lenz & Staehelin (Zurich)
Introduction The Swiss Competition Commission (“ComCo”) fined Stöckli Swiss Sports (“Stöckli”), a Swiss manufacturer of Skis and other sport products, for vertical price fixing with its dealers with CHF 140’000. The fine was rather low, as Stöckli had filed a leniency application, albeit (...)

The Australian Federal Court imposes a record fine on a shipping company guilty of cartel conduct due to the length, serious nature, and economic importance of the market (Kawasaki Kisen Kaisha)
Herbert Smith Freehills (Melbourne)
Kawasaki Kisen Kaisha Ltd (K-Line) has received the largest criminal fine imposed under the Competition and Consumer Act, after pleading guilty to criminal cartel conduct in 2018. Justice Wigney of the Federal Court stated that the penalty “should send a powerful message to multinational (...)

The Portuguese Competition Authority imposes a record fine of €54 million for a cartel in the markets for insuring workplace accidents, health, and cars (Lusitania / Zürich)
Van Bael & Bellis (Brussels)
On 1 August 2019, the Portuguese competition authority (Autoridade da Concorrência, “AdC”) published a press release in which it announced that it had imposed total fines of € 42 million on two insurance companies (Lusitania and Zürich), two board members and two directors for, inter alia, (...)

The Italian Competition Authority fines several companies having implemented two anticompetitive agreements in the market for corrugated cardboard sheets and in the market for corrugated cardboard packaging (Pro-Gest / Cartonstrong Italia / Ondulato Trevigiano / Ondulati Maranello...)
Italian Competition Authority (Rome)
ICA: corrugated cardboard, fines of over €287 million for the main manufacturing companies* On 17 July 2019, the Antitrust Authority concluded an investigation, finding that two separate agreements had been implemented to distort the competitive dynamics in the market for corrugated (...)

The EU Commission fines a company €6.2 million for restricting cross-border sales of merchandising products (Sanrio)
Van Bael & Bellis (Brussels)
On 9 July 2019, the Japanese company Sanrio was fined € 6.2 million by the European Commission (“Commission”) for infringing Article 101 Treaty on the Functioning of the European Union by restricting cross-border sales by its licensees. According to the Commission’s press release, the case (...)

The EU Commission fines a company for restricting cross-border sales of merchandising products (Sanrio)
European Commission - DG COMP (Brussels)
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Gómez-Acebo & Pombo (Brussels)
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Basic-Fit (Hoofddorp)
The investigation of the Commission has found that Sanrio banned traders from selling licensed merchandise of Hello Kitty and other characters outside their territorial coverage but within the European Economic Area (“EEA”). Sanrio is a Japanese company that designs, licenses, produces and (...)

The EU Commission fines a company €6.2M for restricting cross-border sales of merchandising products featuring their brand characters (Sanrio)
European Commission - DG COMP (Brussels)
Antitrust: Commission fines Sanrio €6.2 million for restricting cross-border sales of merchandising products featuring Hello Kitty characters* The European Commission has fined Sanrio €6.2 million for banning traders from selling licensed merchandise to other countries within the EEA. This (...)

The EU Commission imposes a fine of €1.07 billion on five banks for participating in two foreign exchange spot trading cartels in the banking sector (Barclays / RBS / Citigroup / JPMorgan / MUFG)
Bird & Bird (Brussels)
On 16 May 2019, in two settlement decisions, the European Commission ("EC") has fined Barclays, RBS, Citigroup, JPMorgan and MUFG 1.07 billion EUR for participating in two foreign exchange spot trading cartels (see EC press release here). “Foreign exchange spot-trading activities are one of (...)

The EU Commission fines five banks for participating in foreign exchange spot trading cartel (Barclays / RBS / Citigroup / JPMorgan / MUFG)
European Commission - DG COMP (Brussels)
Antitrust: Commission fines Barclays, RBS, Citigroup, JPMorgan and MUFG €1.07 billion for participating in foreign exchange spot trading cartel* In two settlement decisions, the European Commission has fined five banks for taking part in two cartels in the Spot Foreign Exchange market for 11 (...)

The Spanish Competition Authority imposes fines totalling € 118 million on railway infrastructure companies for participating in a cartel (Alstom / Bombardier / Cafs / Cobra / Nokia...)
Van Bael & Bellis (Brussels)
On 14 March 2019, the Spanish competition authority (“CNMC”) imposed fines totalling € 118 million on fifteen companies, namely Cobra, Elecnor, Siemens, Semi, Inabensa, Alstom, Cymi, Isolux, Electren, Comsa, Indra, Neopul, Telice, Eym and Citracc, for their involvement in a cartel on the (...)

The Spanish Competition Authority fines 15 companies €188 million for colluding in public tenders in the railway market (Alstom / Bombardier / Cafs / Cobra / Nokia...)
Bird & Bird (Madrid)
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Ecija & Asociados (Madrid)
On 14 March 2019, the Spanish Competition Authority ("CNMC") fined Siemens, Alstom and 13 other companies with a total of 118 million euros for colluding in public tenders convened by the Spanish Administrator of Railways of Infrastructures (“ADIF”). The CNMC has identified three separate (...)

The EU Commission fines car safety equipment suppliers € 368 million in cartel settlement for illegal information exchanges (Takata / Autoliv / TRW)
European Commission - DG COMP (Brussels)
Antitrust: Commission fines car safety equipment suppliers € 368 million in cartel settlement* The European Commission has fined Autoliv and TRW a total of € 368 277 000 for breaching EU antitrust rules. Takata was not fined as it revealed the cartels to the Commission. The companies took (...)

The EU Commission imposes fines totalling € 368 million on car safety equipment suppliers in cartel settlement decision (Takata / Autoliv / TRW)
Van Bael & Bellis (Brussels)
On 5 March 2019, the European Commission (the “Commission”) announced that it had imposed total fines of € 368,277,000 on two car safety equipment suppliers, Autoliv and TRW, for their involvement in two cartels concerning the supply of car seatbelts, airbags and steering wheels to European (...)

The UK FCA issues its first formal decision under its competition law enforcement powers by fining three asset management firms in an IPO context (Hargreave / Newton / RAMAM)
Hg Capital (London)
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Freshfields Bruckhaus Deringer (London)
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Freshfields Bruckhaus Deringer (London)
On 21 February 2019, the Financial Conduct Authority (FCA) issued a decision finding that three asset management firms breached competition law in the context of an initial public offering (IPO). This marks the FCA’s first formal decision under its competition law enforcement powers, which it (...)

The UK FCA makes the first use of its enforcement powers under competition law and in a landmark decision fines 3 asset managers for exchanging "strategic" information (Hargreave / Newton / RAMAM)
White & Case (London)
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White & Case (Brussels)
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Stephenson Harwood
This article has been nominated for the 2020 Antitrust Writing Awards. Click here to learn more about the Antitrust Writing Awards. Summary In a landmark decision on 21 February 2019 (the “Decision”), marking the first use of its enforcement powers under the Competition Act 1998 (“CA (...)

The Romanian Competition Authority fines six undertakings for an anticompetitive agreement in the market of maintenance services required for ship equipment (Japan Radio / Alphatron Marine / Space Electronics / Alhoutyam / Navtron / Polar Denizcilikve Deniz Malzemeleri)
Romanian Competition Council (Bucharest)
The Competition Council sanctioned with 2 million euro six companies for anticompetitive agreements* The Competition Council sanctioned with fines totalling 9,002,621.75 lei (approx. 2 million Euro) for an anti-competitive agreement aiming at the limitation of marketing of the maintenance (...)

The Indian Competition Authority fines 2 sellers of dry cell batteries for participating in bilateral "ancillary" cartel from the standpoint of consumers (Panasonic / Godrej / Boyce)
Vaish Associates Advocates (New Delhi)
CCI imposes penalty on Godrej and Boyce for being a member of bilateral “ancillary” cartel* The Competition Commission of India (“CCI/ Commission”), by way of order dated 15.01.2019, has imposed a penalty of INR 85,01,364/-on Godrej and Boyce manufacturing Co. Limited (“Godrej”) for acting (...)

The Italian Competition Authority fines several automotive constructors for cartel agreements in the market of car sales through financing (Banca / Banque PSA / Santander Consumer Bank / BMW Bank)
Italian Competition Authority (Rome)
Car sales through financing: ICA sanctions cartel among leading operators imposing fines of over 670 million euros* On 20 December 2018, the Italian Competition Authority concluded an investigation launched against the leading captive banks and related automotive groups operating in Italy in (...)

The German Competition Authority imposes a fine of €1.4 million on asphalt producers for cartel agreements (Gaul / Südhessische Asphalt-Mischwerke / Mitteldeutsche Hartstein-Industrie)
German Competition Authority (Bonn)
Bundeskartellamt imposes fine of approx. 1.4 million euros on asphalt producers and reviews association guidelines for setting up supplier consortia* The Bundeskartellamt has imposed a fine amounting to 1.43 million euros on Gaul GmbH, a manufacturer of asphalt mixes, for participating in a (...)

The French Competition Authority carries out unannounced inspections in the sectors of engineering, technology consulting, IT services and software publishing
Autorité de la concurrence (Paris)
The General Rapporteur of the Autorité de la concurrence indicates that unannounced inspections have been carried out yesterday in the sectors of engineering and technology consulting, IT services and software publishing* Following authorization from the liberty and custody judge, the (...)

The Indian Competition Authority exonerates parties from allegations of cartelization despite admission of coordination in the flashlight market (Eveready / Panasonic / Indo National / Geep / AIDCM)
Vaish Associates Advocates (New Delhi)
CCI holds that mere information exchange by itself is not anti-competitive, in spite of leniency applications filed* The Competition Commission of India (”CCI”) by way of an order dated November 6, 2018 has exonerated Eveready Industries India Limited (“Eveready”), Panasonic Energy India Co. (...)

The Hellenic Competition Authority decides that companies in the market of electrical installations were participating in horizontal agreements by fixing minimum or fixed fees (National Federation of electricians’ unions)
Kyriakides Georgopoulos (Athens)
HCC / SECTION OF ELECTRICAL INSTALLATION MARKET HCC (670/2018) I. HCC decided in Plenum, in a clear majority open vote, under the simplified settlement procedure of Article 25a of Law 3959/2011, in light of its formal Decision under No 628/2016 , that the Secondary Federation of (...)

The UK Competition Authority launches a new campaign "Stop Cartels" to educate businesses about anticompetitive practices and encourage leniency
MemeryCrystal (London)
COMPETITION & MARKETS AUTHORITY GETS TOUGH ON CARTELS* On 22 October 2018, the UK’s Competition and Markets Authority (CMA) announced that it had launched a new “Stop Cartels” campaign to educate businesses about anti-competitive practices and encourage people to come forward if they (...)

The Russian Competition Authority’s Appeal Board dismisses the decision by its Regional Office in Sverdlovsk ordering a leniency applicant to return unlawfully gained income (Krust)
ALRUD (Moscow)
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ALRUD (Moscow)
Unprecedented Russian Law Enforcement: Obligation to Return Unlawfully Gained Income When Using a Leniency Program* The Regional office of the Federal Antimonopoly Service of the Sverdlovsk region has recently issued a decision ordering a leniency applicant to return unlawfully gained (...)

The UK Competition Authority fines an airport for restricting competition on parking prices in a lease with the operator of a Terminal hotel (Heathrow / Arora)
UK Competition & Markets Authority - CMA (London)
Heathrow and Arora admit to anti-competitive car park agreement* Heathrow airport will pay a £1.6m fine for restricting competition on parking prices in a lease with the operator of a Terminal 5 hotel. The fine to be imposed by the Competition and Markets Authority (CMA), comes after its (...)

The Hungarian Competition Authority reduces fines of companies sanctioned for bid-rigging in the radiology IT products market (GE Hungary / Silver Woo)
Hungarian Competition Authority (Budapest)
Substantial reduction of fine thanks to cooperation of the parties* The Hungarian Competition Authority (Gazdasági Versenyhivatal, hereinafter GVH) found that GE Hungary Kft. and Silver Wood – IT Kft. had committed a competition law infringement in the course of purchasing the radiology IT (...)

The Indian Competition Authority fines seller of dry cell batteries for participating in bilateral "ancillary" cartel from the standpoint of consumers (Panasonic / Geep Industries India)
Vaish Associates Advocates (New Delhi)
Competition Commission of India (CCI) imposes penalty on Geep Industries for being a member of bilateral “ancillary” cartel* By way of order dated August 30, 2018, the CCI imposed a penalty of INR 9,64 06,682 (Nine crores sixty-four lakh six thousand six hundred and eight two) on Geep (...)

The EU Commission fines consumer electronics manufacturers a total of €111 million for resale price maintenance, granting substantial reductions in the fines through the cooperation procedure (Asus / Denon & Marantz / Philips / Pioneer)
Van Bael & Bellis (Brussels)
According to a press release and statement issued on 24 July 2018, the European Commission has, in four separate decisions, fined consumer electronics manufacturers Asus, Denon & Marantz, Philips and Pioneer a total of €111 million for engaging in resale price maintenance during periods (...)

The EU Commission fines manufacturers of electronic goods for resale price maintenance (Asus / Denon & Marantz / Philips / Pioneer)
McDermott Will & Emery (Brussels)
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McDermott Will & Emery (Paris)
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Norton Rose Fulbright (Brussels)
Vertical restrictions, including resale price maintenance (RPM), have not generally been an EC enforcement priority over the last 10 years, but a series of rulings in July 2018 signalled a potential change in that trend. Although the EC considers RPM to be a “hardcore restriction” of (...)

The EU Commission fines manufacturers over €111 million for restricting the ability of online retailers to set their retail prices for a variety of widely-used consumer electronics products (Asus / Denon & Marantz / Philips / Pioneer)
Bona Law (San Diego)
Antitrust News: The European Commission imposes fines for the first time in 15 years as a result of online retail price restrictions (RPM)* On July 24, 2018, the European Commission fined manufacturers Asus, Denon & Marantz, Philips and Pioneer for over €111 million for restricting the (...)

The EU Commission fines four leading consumer electronics manufacturers for fixing online resale prices (Asus / Denon & Marantz / Philips / Pioneer)
MemeryCrystal (London)
EU COMMISSION FINES MAJOR CONSUMER ELECTRONICS MANUFACTURERS FOR FIXING ONLINE RESALE PRICES* On 24th July 2018 the EU Commission passed a decision to enforce the competition rules in yet another case involving the e-commerce sector. This time it fined a number of leading consumer (...)

The Indian Competition Authority decides its fourth leniency and fines broadcasting service providers for bid-rigging in tenders floated by sports broadcasters (Essel Shyam Communication / Globecast India / Globecast Asia)
Vaish Associates Advocates (New Delhi)
CCI decides its fourth leniency, imposes penalty on broadcasting service providers for bid-rigging in tenders floated by Sports Broadcasters* By way of an order dated 11 July 2018, the Competition Commission of India (CCI) imposed a penalty of INR 22.36 Crore on Essel Shyam Communication (...)

The Moldovan Competition Authority grants immunity from fine to a leniency applicant in a bid rigging case (Litarcom / Capillati / Ecosem Grup)
University of Macau - Faculty of Law
On 5 July 2018, the Competition Council of the Republic of Moldova (CC) found the signs of bid rigging in the public procurement, organized by local administration in the Glodeni county. The CC initiated its investigation on the basis of the leniency application filed by Ecosem Grup SRL, (...)

Unilateral Practices

The Czech Competition Authority fines a kitchen equipment manufacturer for resale price maintenance (TESCOMA)
Czech Competition Authority (Brno)
THE OFFICE IMPOSED A FINE OF ALMOST CZK 64,000,000 ON TESCOMA FOR RESTRICTING PRICE COMPETITION BETWEEN RETAILERS* The Office for the Protection of Competition (hereinafter referred to as “the Office”) imposed a fine of CZK 63,952,000 on TESCOMA s.r.o. (hereinafter referred to as "TESCOMA") (...)

The Polish Competition Authority initiates preliminary proceedings against the sole importer of coffee machines over allegations of price fixing (Jura Polska)
Polish Competition Authority (Warsaw)
Coffee machines - preliminary proceedings* President of UOKiK, Tomasz Chróstny, has initiated preliminary proceedings regarding possible price fixing for Jura coffee machines. Currently the evidence collected in this case in the course of the search is being reviewed. As part of the (...)

The Polish Competition Authority fines a German manufacturer of vacuum cleaners for resale price maintenance (Karcher)
Polish Competition Authority (Warsaw)
Karcher - fine for long-standing collusion* Sales prices of cleaning devices and systems of the Kaercher brand have been artificially inflated for more than 20 years. President of UOKiK Tomasz Chróstny imposed a fine of PLN 26 million on the Karcher company. The penalty would be significantly (...)

The Chinese SAMR fines a national pharmaceutical company $1.4M for resale price maintenance (Geistlich Trading)
AnJie Broad Law (Beijing)
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AnJie Broad Law (Beijing)
Beijing AMR fines Geistlich Trading (Beijing) over monopoly agreement* On 28 February 2022, the State Administration for Market Regulation (SAMR) published an administrative penalty decision against Geistlich Trading (Beijing) Co Ltd for engaging in monopoly agreements of resale price (...)

The US DoJ announces that a ready-mix concrete company admitted to fixing prices and rigging bids (Argos USA)
US Department of Justice (Washington)
Ready-Mix Concrete Company Admits to Fixing Prices and Rigging Bids in Violation of Antitrust Laws* Argos USA LLC, a producer and seller of ready-mix concrete headquartered in Alpharetta, Georgia, was charged with participating in a conspiracy to fix prices, rig bids, and allocate markets (...)

The Croatian Competition Authority fines a business-to-business food re-seller for imposing unfair trading practices on its suppliers but reduces the fine in light of cooperation, the company’s small size, and the company’s importance for the national island tourism sector (Jadranka trgovina)
Croatian Competition Agency (Zagreb)
Unfair Trading Practices: CCA imposes HRK 85,000 fine on Jadranka trgovina* The Croatian Competition Agency (CCA) opened three ex officio infringement proceedings against Jadranka trgovina within the meaning of the Act on prohibition of unfair trading practices in the business-to-business (...)

The Polish Competition Authority fines a manufacturer of musical equipment for resale price maintenance (Yamaha Music Europe)
Polish Competition Authority (Warsaw)
Decision of the President of UOKiK on overpricing of Yamaha musical equpiment* For 13 years, Yamaha Music Europe has been setting minimum prices for resale of musical equipment in online stores in Poland with its distributors. President of UOKiK Tomasz Chróstny imposed a fine of half a (...)

The Croatian Competition Authority fines a food re-seller for imposing unfair trading practices on its suppliers including consistent late payment of supply invoices (Ribola)
Croatian Competition Agency (Zagreb)
Unfair Trading Practices – CCA Imposes Hrk 65,000 Fine on Ribola* The Croatian Competition Agency (CCA) opened ex officio infringement proceeding within the meaning of the Act on prohibition of unfair trading practices in the business-to-business food supply chain (UTPs Act) with the view to (...)

The Turkish Administrative Court upholds the fines imposed by the Competition Authority on two electricity sales companies for abuse of dominance (Rescs / Ayedas)
ELIG Gürkaynak Attorneys-at-Law (Istanbul)
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Balcıoğlu Selçuk Akman Keki (BASEAK) (Istanbul)
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ELIG Gürkaynak Attorneys-at-Law (Istanbul)
(1) Introduction In 2018, in its Enerjisa decision, the Turkish Competition Board (“ Board ”) had imposed administrative fines amounting to a total of TRY 143 million on three retail electricity sales companies (namely AYESAŞ, BAŞKENT and TOROSLAR) (together, the “ RESCs ”) and one (...)

The Chinese State Administration for Market Regulation sees new provisions on monopolistic agreements and abuse of dominance enter into force
Lang Yue (Beijing)
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Zhao Sheng (Beijing)
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Linklaters (Beijing)
This article has been nominated for the 2020 Antitrust Writing Awards. Click here to learn more about the Antitrust Writing Awards. On September 1, 2019, two sets of provisions on antitrust enforcement under the Anti-Monopoly Law (AML) (反垄断法) issued by China’s State Administration for (...)

Mergers

The Spanish Competition Authority investigates unauthorized merger operations and antitrust practices in the funeral insurance and funeral services sectors
Spanish Competition Authority (CNMC) (Madrid)
The CNMC investigates the possible execution of unauthorised mergers, as well as potential antitrust practices involving the funeral insurance and funeral services markets.* From 8 to 10 September, dawn raids were carried out at the headquarters of various companies active in the aboved (...)

The French Competition Authority publishes its adaptation of the time limits and procedures during the COVID-19 outbreak
Autorité de la concurrence (Paris)
Adaptation of the time limits and procedures of the Autorité de la concurrence in times of health emergency* Background The Autorité specifies to businesses how the rules regarding deadlines and procedures will be adapted due to the state of health emergency. Following the adoption of (...)

The Irish Competition Authority uses criminal sanctions against companies for gun jumping (Armalou / Airfield)
An Post (Dublin)
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Matheson (Dublin)
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Arthur Cox (Dublin)
Summary In this case update, we discuss a 2019 criminal enforcement case in Ireland brought by the Competition and Consumer Protection Commission (the “CCPC”) in conjunction with the Director of Public Prosecutions (the “DPP”), in relation to breaches of procedural merger control law under (...)

Procedures

The Austrian Competition Authority files an application with the Cartel Court to impose a fine of €4.8M on a construction cartel, and to find that a leniency applicant committed an infringement (Pittel / Brausewetter / Kostmann)
Austrian Competition Authority (Vienna)
Construction cartel UPDATE – AFCA files application for a fine on Pittel + Brausewetter and for findings on Kostmann* In the course of its investigations into the Austrian construction industry, the Austrian Federal Competition Authority (AFCA) filed another application on 21 February 2023 (...)

The Turkish Competition Authority publishes pioneer decisions on simultaneous implementation of leniency and settlement procedures (Beypazarı) (Kınık)
ACTECON (Istanbul)
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ACTECON (Istanbul)
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ACTECON (Istanbul)
Following the introduction of the settlement procedure, the number of undertakings applying for settlement has been increasing consistently. In this respect, the Turkish Competition Authority’s (“TCA”) evaluations regarding the implementation of the settlement procedure have become an object (...)

The Spanish Competition Authority announces its intention to start including directly in its decisions the scope and duration of procurement bans imposed on parties involved in cartel infringements
Herbert Smith Freehills (Madrid)
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Herbert Smith Freehills (Madrid)
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Herbert Smith Freehills (Madrid)
On 24 November 2022, Spain’s National Markets and Competition Commission (Comisión Nacional de los Mercados y la Competencia, “CNMC”) announced its intention to start including directly in its decisions the scope and duration of procurement bans imposed on parties involved in cartel (...)

The Lithuanian Competition Authority updates the fine-setting procedure by improving the incentive to cooperate with the Competition Authority during infringement investigations
Lithuanian Competition Authority (Vilnius)
PROCEDURE FOR SETTING FINES FOR COMPETITION LAW INFRINGEMENTS HAS BEEN IMPROVED* Today the Lithuanian Government adopted a resolution approving the description of the procedure for setting fines for infringements of the Law on Competition. A more detailed regulation of the methodology for (...)

The EU Commission updates its Guidance on the practice and policy of obtaining leniency in cartel cases
Herbert Smith Freehills (Brussels)
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Herbert Smith Freehills (Brussels)
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Herbert Smith Freehills (Brussels)
Seeking to clarify its policy and encourage leniency applicants to come forward, the European Commission ("Commission") has published new guidance on its approach to leniency and its Leniency Notice. The new guidance comes in the form of Frequently Asked Questions ("FAQs"). The FAQs provide (...)

The EU Commission publishes Guidance on its leniency policy and practice
Van Bael & Bellis (Brussels)
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 (...)

The EU Commission provides guidance on its leniency policy and practice
European Commission - DG COMP (Brussels)
Antitrust: Commission provides guidance on its leniency policy and practice* The European Commission has published guidance that aims to facilitate leniency applications by providing further transparency, predictability and accessibility to potential leniency applicants. The Commission’s (...)

The EU Commission upgrades eLeniency tool to grant companies online access to leniency and settlement documents (eLeniency)
European Commission - DG COMP (Brussels)
Antitrust: Commission upgrades eLeniency tool to grant companies online access to leniency and settlement documents* The European Commission has upgraded its online platform “eLeniency” to ensure that companies who are parties to cartel and antitrust proceedings can easily and securely (...)

The Latvian Competition Authority changes the procedure for the calculation of fines for infringements of competition law
Latvian Competition Council (Riga)
Changes to the procedure for determining fines applicable by the CC* On August 26, 29.03.2016. amendments to the Cabinet of Ministers regulation No. 179 " Procedures for Determining a Fine for the Infringements Provided for in Section 11, Paragraph One, Sections 13 and 14.1 of the (...)

The EU General Court confirms the case law on the presumption of innocence in cartel cases where only some parties are given leniency for cooperation (Scania)
Van Bael & Bellis (Brussels)
On 2 February 2022, the General Court of the European Union delivered a judgment in which it upheld the European Commission’s (“Commission”) decision to impose a fine of €880.5 million on Scania for participating in a cartel for 14 years with five other truck manufacturers (Case T-799/17, (...)

The EU Court of Justice AG Bobek proposes a unified test for the protection against double jeopardy under the EU Charter of Fundamental Rights (bpost / Nordzuck)
European Court of Justice (Luxembourg)
Advocate General Bobek proposes a unified test for the protection against double jeopardy (ne bis in idem) under the EU Charter of Fundamental Rights* That test should rely on a threefold identity: of the offender; of the relevant facts; and of the protected legal interest A Belgian and an (...)

The French Competition Authority revises its procedural notice on the method for determining fines after the transposition of the ECN+ Directive
Autorité de la concurrence (Paris)
The Autorité de la concurrence revises its procedural notice on fines* Background The Autorité is today publishing a new procedural notice on the method for determining fines, which repeals and replaces the previous notice of 16 May 2011. This new notice was the subject of a public (...)

The EU Court of Justice clarifies conditions for the granting of partial immunity under the 2006 Leniency Notice (Recylex)
European Commission - DG COMP (Brussels)
In a judgment delivered on 3 June 2021, the European Court of Justice (the “ECJ”) dismissed the appeal brought by Recylex against the judgment of the General Court which had upheld the European Commission’s (“Commission”) decision finding it and three other companies to have infringed Article (...)

The EU Court of Justice dismisses an appellant’s plea to adjust its ranking in a leniency process and to receive partial immunity for its participation in a car battery recycling cartel (Recylex)
Covington & Burling (Brussels)
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Covington & Burling (Brussels)
On 3 June 2021, the European Court of Justice (“ECJ”) in case C-563/19 P Recylex v Commission dismissed Recylex’ appeal both to adjust its ranking in the leniency process and to receive partial immunity for parts of its participation in the Car Battery Recycling cartel. The judgment, on (...)

The UK Competition Authority lowers discount in fines for resale price maintenance leniency applicants
Van Bael & Bellis (Brussels)
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Van Bael & Bellis (Brussels)
On 24 September 2020, the UK’s Competition and Markets Authority (“CMA”) modified its leniency guidelines so that companies that apply for leniency after the opening of a retail price maintenance (“RPM”) investigation should only expect to receive a maximum 50% discount in fines. Previously, (...)

The Chinese Competition Authority publishes anti-monopoly guidelines on leniency and commitments
Jones Day (Shanghai)
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Jones Day (Beijing)
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Jones Day (Beijing)
The Anti-Monopoly Bureau of China’s State Administration for Market Regulation (“SAMR”) released four sets of long-awaited anti-monopoly guidelines. This White Paper addresses the Guidelines on Application of Leniency Program in Horizontal Monopoly Agreement Cases and the Guidelines on (...)

The Chinese State Administration for Market Regulation publishes anti-monopoly guidelines on leniency and commitments
Jones Day (Shanghai)
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Jones Day (Beijing)
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Jones Day (Beijing)
This article has been nominated for the 2021 Antitrust Writing Awards. Click here to learn more about the Antitrust Writing Awards. The Anti-Monopoly Bureau of China’s State Administration for Market Regulation (“SAMR”) released four sets of long-awaited anti-monopoly guidelines. This White (...)

The Chinese State Administration for Market Regulation breaks new ground with book for antitrust guidelines
Hogan Lovells (Beijing)
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Hogan Lovells (Hong Kong)
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Hogan Lovells Fidelity (Shanghai)
On 6 August 2020, the lid was lifted on one of China’s biggest antitrust secrets. On that day, news broke out that a new book authored by the State Administration for Market Regulation ("SAMR") featuring a compilation of antitrust rules had been launched. The compilation contains four (...)

The Chinese State Administration for Market Regulation publishes leniency guidelines
AnJie Broad Law (Beijing)
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AnJie Broad Law (Beijing)
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AnJie Broad Law (Beijing)
Highlights of the Chinese Leniency Guidelines Published by SAMR in June 2020* In June 2020, the Anti-Monopoly Bureau of the State Administration for Market Regulation (“SAMR”) published a new book, the 2019 Compilation of Antitrust Regulations and Guidelines, which contains four previously (...)

The Polish Competition Authority clarifies its principles for fining managers found responsible for concluding restrictive agreements
Polish Competition Authority (Warsaw)
The President of UOKiK’s principles of imposing fines on managers* Managers responsible for concluding restrictive agreements are liable to a financial fine of up to PLN 2 million. On konkurencja.uokik.gov.pl we have published explanations on the principles for determining the amount of (...)

The Lithuanian Competition Authority updates rules on fines and adopts rules on cooperation with EU counterparts
Lithuanian Competition Authority (Vilnius)
Lithuanian Competition Authority updates rules on immunity from fines or their reduction and adopts rules on cooperation with EU counterparts* In relation to the amendments to the Law on Competition adopted by the Seimas, today the Lithuanian competition authority Konkurencijos taryba has (...)

The Egyptian Competition Authority publishes guidelines for obtaining amnesty or leniency from criminal prosecution for antitrust cartel violations
White & Case (Washington)
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White & Case (Washington)
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White & Case (Cairo)
The Egyptian Competition Authority recently published the first Egyptian guidelines on the process for obtaining amnesty or leniency from criminal prosecution for antitrust cartel violations, signaling the agency’s intent to activate this tool in future enforcement activities. The guidelines (...)

The Japanese FTC issues a draft of amendments on the calculation of fines and reformation of the leniency system and seeks comments from the public
White & Case (Tokyo)
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White & Case (Tokyo)
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White & Case (Tokyo)
On June 29, 2020, the Japan Fair Trade Commission (“JFTC”) issued a draft of amendments to relevant cabinet orders and rules (“Drafts”) in accordance with the amendments to the Anti-Monopoly Act (“AMA”) previously passed in June 2019 (“2019 AMA Amendments” or “Amendments”). The JFTC is (...)

The US DoJ welcomes the Congressional reauthorization of the Antitrust Criminal Penalty Enhancement and Reform Act
US Department of Justice (Washington)
Department of Justice Applauds Congressional Passage Of Reauthorization Of The Antitrust Criminal Penalty Enhancement And Reform Act* On June 25, the U.S. House of Representatives and Senate passed identical bills, H.R. 7036 and S. 3377, to repeal the sunset provision of the Antitrust (...)

The Lithuanian Parliament amends the Competition Act with regard to such matters as independence, resources, powers and sanctions, in line with provisions of the Directive of the EU Parliament and Council
Lithuanian Competition Authority (Vilnius)
Competition Law Amendments Will Ensure More Effective Competition Enforcement in Lithuania* Today Seimas adopted amendments to the Law on Competition which will transpose the provisions of the Directive of the European Parliament and Council into national law, ensuring uniform regulation of (...)

The US Congress approves the renewal and permanent extension of the Antitrust Criminal Penalty Enhancement and Reform Act
Skadden, Arps, Slate, Meagher & Flom (New York)
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Skadden, Arps, Slate, Meagher & Flom (New York)
On June 25, 2020, Congress approved the renewal and permanent extension of the Antitrust Criminal Penalty Enhancement and Reform Act (ACPERA or “the Act”), which limits the civil damages exposure of companies that cooperate with the Department of Justice (DOJ) in selfreporting their own (...)

The Spanish Competition Authority publishes antitrust compliance programme guidelines
Callol, Coca & Asociados (Madrid)
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Latham & Watkins (Brussels)
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Callol, Coca & Asociados (Madrid)
The National Competition and Markets Commission (CNMC) has published a guide on competition law compliance programs (Guide). The Guide draws on two legal developments: (i) the prohibition of contracting with public administrations in the case of companies found guilty of infringing the (...)

The Japanese FTC publishes new draft rules and guidelines establishing limited confidentiality protections for attorney-client in certain investigations
Morrison & Foerster (Tokyo)
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Morrison & Foerster (Tokyo)
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Morrison & Foerster (Tokyo)
Japan FTC Proposes New Attorney-Client Privilege Rules for Public Comment* In April 2020, Japan’s antitrust regulator, the Japan Fair Trade Commission (JFTC), issued draft rules and guidelines establishing, among other things, limited confidentiality protections for attorney-client (...)

The EU Commission announces the launch of its new online tool for companies to submit statements and documents in leniency and settlements proceedings (eLeniency)
Bird & Bird (Brussels)
On 19 March 2019, the European Commission (“EC”) announced the launch of "eLeniency", its new online tool for companies to submit statements and documents in leniency and settlement proceedings in cartel and in non-cartel proceedings under Articles 101 and 102 TFEU, where an undertaking (...)

The UK Competition Authority publishes guidance for competition disqualification orders against directors
Bird & Bird (London)
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Bird & Bird (London)
In the event of a UK competition law infringement, the CMA can seek a Competition Disqualification Order ("CDO") for up to 15 years against (i) any director of company who has committed a breach of competition law and (ii) if the court considers that the individual’s conduct as a director (...)

The EU Data Protection Supervisor, Commission and Parliament clarify how data protection laws apply to competition investigations
McDermott Will & Emery (Paris)
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Norton Rose Fulbright (Brussels)
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McDermott Will & Emery (Brussels)
The application of the GDPR from 5 May 2018 has had a significant impact on the way companies manage their data in various areas. In the field of competition, the GDPR might well cause companies that face competition investigations to wonder whether they should provide personal data in (...)

The Canadian Competition Authority and the Public Prosecution Service jointly launch revised immunity and leniency programs
Conzen O’Connor (Toronto)
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Cassels Brock & Blackwell (Toronto)
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Cassels Brock & Blackwell (Toronto)
It used to be the best deal in town: participants in criminal price-fixing conspiracies could approach the Competition Bureau and receive either complete immunity or leniency in exchange for ratting out their co-conspirators. The Bureau and the Public Prosecution Service of Canada (PPSC) (...)