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