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On the subject of anti-cartel enforcement at the EU level, Peter Willis and Victoria Ross provide an interesting review of the applications for leniency pursuant to the European Commission’s 2002 Notice on immunity from fines and reduction of fines in cartel cases. The EU leniency policy has proved enormously successful since its introduction in 1996. However, the authors draw attention to a number of interesting practical points, including the fact that leniency applicants who were not ‘first in through the door’ of DG COMP might have done better to not seek leniency and rely instead on securing reductions for co-operation outside the scope of the 2002 Notice.
Peter Willis and Victoria Ross
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