Cartel / Price-Fixing and Dawn Raids

Antitrust News & Briefs  

The rapid and dramatic expansion of cartel enforcement across multiple jurisdictions is among the most significant developments in antitrust enforcement over the past decade.  Companies now face simultaneous or serial enforcement actions not only in the United States and the European Union, but also in Asia and in emerging markets across the globe.  Steptoe’s transatlantic antitrust team has the ability to respond to an investigation immediately, helping our clients develop a unified global strategic defense. 

Involvement in cartel behavior can have serious consequences for a company due to the high levels of fines and the growing threat of private damages actions.  Further, in many jurisdictions, officers of a company involved in cartels face individual criminal sanctions or other penalties.  We offer clients a wide range of services specifically designed for an international cartel defense, covering:

  • “Dawn raids” by US, EU, and other national authorities (see our emergency contact information)
  • Amnesty/leniency applications
  • Criminal and administrative investigations by US, EU, and national authorities
  • Criminal defense and appeals in court proceedings in the US and EU
  • Criminal defense of individuals
  • Civil damages litigation in US and EU Member States
  • Class action proceedings in the US
  • Compliance programs
  • Securities and stock exchange disclosures
  • Labor and employment issues
  • Directors’ liability
  • US Government, World Bank, and other contract debarment proceedings
  • International criminal law representation including extradition issues
  • Whistle-blowing issues

Our antitrust team also often collaborates with Steptoe's white-collar criminal defense practice—one of the most well-respected in Washington and New York— to provide defense in criminal trials of corporations and top management in the US. 

Representative Matters

  • Defense of a Japanese auto parts maker in US bid-rigging investigation and related US criminal trial against competitor.
  • Defense of a leading airline in a multi-national price-fixing investigation; US, EU, and Swiss authorities.
  • Defense of a leading chemical company in a multi-jurisdictional cartel investigation into rechargeable batteries.
  • Representing a national industry association alleged to be a co-conspirator in treble-damages class actions alleging price fixing and monopolization in the dairy industry of the southeastern US.
  • Representing food and food processing companies in various cartel investigations in France.
  • Representing a major railroad in treble-damages class actions alleging price fixing of fuel surcharges.
  • Defense of a leading Asian airline in US treble-damages class actions associated with ongoing multi-national criminal cartel investigations.
  • Defending a major specialty chemical company in treble-damage class actions alleging price-fixing of certain intermediate chemicals.
  • Defending a major industrial chemical manufacturer sued on indirect purchaser claims of price-fixing of chlorine and caustic soda.
  • Representing a major telecommunications equipment manufacturer in a DOJ civil investigation of potential price-fixing, market allocation, and monopolization relating to technology development.
  • Representing a major trade association in several investigations by the FTC and the DOJ relating to allegations of price-fixing and conspiracies to exclude competitors.
  • Defending a rail maintenance group in a French bid-rigging case.
  • Representing an Asia-based automotive parts manufacturer in the European Commission’s ongoing cartel investigations in this sector.
  • Defending a major consumer electronics group in an interim measure case and commitments procedure relating to the structure of its distribution.
  • Representing a major flour producer in French antitrust investigations and related litigation and obtaining the annulment of the dawn raid as well as a positive resolution of the case.
  • Advising and representing an EU-based e-payment solution provider and an EU banking association in the European Commission’s antitrust investigation into e-payments.
  • Advising a payment card group in relation to a French procedure on their multilateral interchange fees and resolving the case through commitments.
  • Securing the early termination of European Commission cartel investigations without the imposition of fines on behalf of a leading Far-East Asian chemical company.
  • Assisting an international group in the European Commission freight forwarding investigation.
  • Representing Japan Airlines in the European Commission investigation into international passenger services between Europe and Japan.
  • Defending Japan Airlines in the airfreight cartel investigation before the European Commission and the Swiss Competition Authority.
  • Representing a freight forwarder in the European Commission freight forwarding cartel investigation.
  • Defending a European glass maker in the European Commission cartel investigations in the flat glass and auto glass industries.
  • Carrying out in-depth audits and analysis of the anti-competitive practices of a large conglomerate in France.
  • Assisting a financial institution in an extensive antitrust risk mapping exercise.


  • Recommended by Legal 500 EMEA 2012 for Competition (Yves Botteman)
  • Who’s Who of Competition Lawyers 2010 and prior years (Ken Ewing)
  • Recommended by Legal 500 US 2009 for Antitrust (Ken Ewing)
  • Washington, DC Super Lawyers 2007 (Ken Ewing: Antitrust Litigation; Robert Fleishman: Antitrust Litigation; David Roll: Antitrust Litigation)

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