It is widely rumored that the U.S. Antitrust Division of the Department of Justice (“Antitrust Division”) is already working toward its next wave of international cartel investigations. The blockbuster auto parts investigation has netted massive fines, jail time, and fugitives, and spawned ripple investigations globally, from China to South Africa. As prosecutions continue and those caught in the net continue to struggle, critical lessons emerge, and not just for the defense. Significantly, the Antitrust Division has been speaking out on compliance, cooperation, and serial offenders.

Those in the trenches see signs that the tidal wave of Antitrust Division auto parts investigations are starting to recede. And the Antitrust Division has promised that we should expect to see enforcement activity in a new area soon. Yet, what could be bigger than auto parts? So far in the U.S. alone...