Cartels 2025

We are delighted to present the 13th edition of Global Legal Insights - Cartels. This edition covers the most significant developments in 17 jurisdictions around the world and, as before, is designed to provide in-house counsel, government agencies and private practice lawyers with a practical insight into cartel enforcement policy and procedure, including leniency/amnesty regimes, administrative settlement, sanctions and appeals.

The aim of this edition, as with other volumes in the Global Legal Insights series, is to collect the views and opinions of a group of leading competition law practitioners from around the world in a single volume. Authors continue to be encouraged to focus their chapter on what they consider to be the most important practice points and recent developments in their jurisdictions, with a free rein to determine the content of their chapter. By giving the authors the opportunity both to select the legal and policy issues that they wish to discuss, and to offer insights into the practical operation of their national regimes, this book aims to look beyond the anti-cartel provisions and enforcement procedures that apply in the various jurisdictions. It also facilitates an up-to-date comparative analysis of the approaches currently being taken by competition agencies around the world to some of the difficult issues that can arise in practice.

This year has seen a continued trend towards renewed enforcement activities by regulators in several jurisdictions, with the number of dawn raids in 2024 staying broadly consistent with the two previous years' figures. Much of the activity seems sector agnostic but there are common underlying issues; for example, price fixing, algorithmic collusion, wage fixing and no poach agreements, and bid rigging, with regulators in several jurisdictions demonstrating a keen interest in potentially anti-competitive conduct in public procurement processes. The total level of fines imposed globally was significantly lower than previous years despite the number of enforcement decisions remaining broadly the same as 2023, with the lowest cartel fines imposed by the European Commission in 20 years. Notably, the European Commission imposed a fine of EUR15.9 million for obstructing its investigation during a dawn raid after a senior staff member deleted WhatsApp messages during the raid. Fines for obstructing dawn raids were also imposed by regulators in Greece and Poland in 2024.

We thank the many authors for their considerable efforts in providing what we hope is a more in-depth look at the global cartels landscape, which we hope will prove to be helpful when considering enforcement initiatives and developments in your own jurisdiction.

Euan Burrows & Denis Fosselard
Ashurst LLP