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Cartel fine totals for 2017 reflect record lows as compared to recent years, particularly for perennial powerhouse enforcers like the United States Department of Justice and European Commission. In the United States, the Department of Justice imposed its lowest fine total in nearly fifteen years of just $119 million. The European Commission fared only modestly better, imposing just $1.4 billion ($1 billion of which was the result of a single fine) as compared to its $4.1 billion total from last year. Across the board, worldwide fine totals typically decreased or held steady from 2016.

Despite the substantial dip in fine figures, there is reason to believe that 2017 may be an anomaly or the proverbial “calm before the storm.” There was no shortage of dawn raids reported in the news in 2017, suggesting last year’s fine totals may simply reflect that regulators are in the early days of the investigative lifecycle of their next generation of cases. There are also reports of large matters on the verge of resolution that if concluded, may result in fine totals rebounding in 2018.