Global Cartel Enforcement Update -

Guidance on Managing International Investigations -

The U.S. Department of Justice’s Antitrust Division has continued to successfully prosecute corporations and individuals for criminal violations of the U.S. antitrust laws, i.e., cartel violations. Both companies and individuals located in Japan and other jurisdictions may be subject to U.S. investigations and prosecution, if their conduct overseas impacts U.S. consumers. For the third year in a row, total cartel fines paid by companies and individuals to the U.S. Department of Justice exceeded $1 billion.

Since 2011, more than $2.5 billion in fines have come from the Antitrust Division’s Auto Parts investigation, in which 36 companies and 30 individual executives have pleaded guilty or agreed to plead guilty to criminal antitrust violations. More than half of the companies and individuals charged in this investigation were from Japan. The significant level of U.S. criminal fines, the broad reach of U.S. antitrust laws, and the coordination among global enforcement agencies have made cartel issues a significant compliance issue in recent years.