Overall, global fines for cartel activity in 2024 (USD602.5 million) were the lowest recorded for several years, and significantly lower than the 2023 total (USD1.9billion). Unlike in previous years, 2024 saw relatively few ‘landmark’ decisions, with no individual fines exceeding USD100m. However, the total number of cartel enforcement decisions remained broadly steady, with 170 decisions issued in 2024 compared with 163 decisions in 2023.
While the lower fine totals may therefore at least in part be indicative of the nature of the cases that reached decision in 2024, as opposed to reflecting a broader reduction in cartel enforcement activity, there remains a view that the proliferation of private enforcement across the U.S., U.K. and EU is having a chilling effect on immunity/leniency applications, and consequently on cartel enforcement. However, regulators have typically been keen to signal that this is not the case. Significantly, a senior official at the The European Commission (EC) confirmed in January 2025 that the EC expects to issue more cartel decisions this year, with a particular focus on unlawful information exchanges and collusion facilitated by new technologies and tools.
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