Overall, the number of immunity/leniency cases decided in 2024 (21) was broadly in line with 2023 (19) and 2022 (18). While certain antitrust authorities anecdotally continue to highlight the impact of leniency programs on cartel detection and deterrence, the costs and uncertainty associated with seeking leniency—including increasingly the prospect of follow-on private litigation and exposure to liability in other jurisdictions—have greatly reduced the leniency pipeline across many jurisdictions globally.
Regulators have continued their efforts to encourage immunity applications and leniency submissions by increasing the attractiveness of their policies. In February 2024, India’s new “leniency plus” framework, designed to incentivize companies already under investigation to report other cartels, came into effect. In March 2024, the U.S. Department of Justice (DOJ) published an update to its leniency policy and procedures to implement a safe harbor for companies that discover wrongdoing by the acquired business in an M&A transaction...
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