Pending Uptick in International Cartel Enforcement Investigations and Cases?

In the past several years, much of the cartel enforcement has focused on domestic companies and executives. Many have asked whether and when international cartel enforcement may pick up.

In January 2024, the highest-ranking criminal enforcement officer in the Antitrust Division reported that:

the Antitrust Division has over 150 grand jury investigations open across its five criminal offices. Over one third of those investigations have an international angle. This reflects the fact that globalization has led to an increase in sophisticated international cartels that threaten markets for key products and services, including our supply chain. (emphasis added)

Whether a return to international cartel enforcement occurs remains to be seen. A large number of active investigations with “an international angle” suggests more cases may be on the way.

(This article originally appeared in the March 2024 Cartel Enforcement Trends and Developments newsletter.)