Cartels are by their nature hard to uncover and
regulators rely – to a large part – on appealing to
companies' wallets. Immunity and leniency policies, by which
regulators offer to whistleblowing companies full immunity or
discounts from fines, have been around for a long time. An
increasing number of regulators have now added another instrument
to their cartel enforcement toolkit: the offering of financial
incentives to lure individual employees to come forward and
whistleblow against their employers or former
employers.
By way of example, the Hungarian Competition Council provides a
reward calculated as a percentage of the cartel fine imposed, with
a maximum limit of HUF 50,000,000 (approximately EUR 155,000 or USD
175,000). Similarly, the Taiwan Fair Trade Commission also offers a
financial reward of potentially up to 20% of the amount of fines
that it recovers. The Korean Fair Trade Commission is reported to
generously offer up to KRW 3 billion (approximately EUR
