1. Introduction
Personal liability rules for the competition law violations and
accordingly, the tracking systems to ensure that the damages caused
are covered/compensated by the violating person from his/her own
resources, have been under the increasing scrutiny of the
competition authorities all around the world and even despite the
discrepancies, some of the EU member states support the idea of
strengthening the individual liability rules by showing a tendency
to criminalize competition enforcement or by vesting the
authorities with the competence to disqualify undertakings'
directors, like in the common law jurisdictions.
In this context, Law No. 4054 on Protection of Competition
("Turkish Competition Law") and
Regulation on Fines to Apply in Cases of Agreements, Concerted
Practices and Decisions Limiting Competition, and Abuse of Dominant
Position ("Turkish Regulation on Fines")
set forth the rules and principles to determine the amount of fine
that will be
