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 competition authorities (“NCAs” or “CAs”).  Leniency programmes are a crucial tool in uncovering cartels, with a large majority of cartel decisions adopted by European competition authorities based on immunity and leniency applications. But for how long? Leniency programmes offer companies involved in cartels the possibility to come forward and bring evidence to competition authorities in exchange for total immunity or leniency (i.e., a reduction of fines). They aim at detecting secret cartels but also at
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