The cartel fine figures for 2024 reflect modest growth in some jurisdictions with steep declines in others when compared to last year. Despite sporadic growth in some areas, figures still lag behind the historic highs of years past, when the U.S., EU and others regularly posted annual fines figures in the billions.
In 2025, we expect global cartel enforcement figures will remain modest, as enforcers continue to work through existing matters, many of which remain focused on procurement collusion and smaller domestic market cases. It remains to be seen whether the shift in administration in the U.S., and the sharpening global enforcement focus on emerging technologies, particularly artificial intelligence, will breathe new life back into enforcement figures heading in 2026.
The report was highlighted by publications including The Wall Street Journal and AmLaw Litigation Daily.
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Trends to Watch for in 2025
Artificial Intelligence as Enforcement Priority
Enforcers around the world are focused on emerging technologies with a particular focus on AI. In 2024, enforcers closely monitored pricing algorithms and AI tools as a new possible means of collusion and information exchange by competitors.
ESG Under the Microscope
With the change in administration, coordinated ESG efforts in the U.S. may be subject to more scrutiny than ever before. Although the Biden administration was reticent to target ESG collaboration using antitrust laws, we may see a change in enforcement strategy under the Trump administration.
The Next Chapter for Employee Rights
In 2024, we saw enforcers continue to pursue potential competition concerns in the labor market, an area not traditionally at the center of enforcement objectives. Enforcers globally scrutinized employment-related agreements, including, for example, no-poach, no-hire, wage-fixing, or non-compete agreements.
Procurement Collusion and Domestic Markets
Despite recent commitments to increasing cross-border cooperation and investigations, global cartel enforcers appear to remain primarily focused on domestic matters.