A new report authored by Simpson Thacher & Bartlett partner John Terzaken argues a decrease in fines collected by antitrust enforcers globally and in the U.S. fails to paint a clear picture of the space’s increasingly intense enforcement environment.
“Belied by low fine totals, all signs point to a continuation of aggressive antitrust enforcement worldwide,” reads Terzaken’s report, the 2023 Global Cartel Forecast, released earlier this month. Before diving into how enforcement actions started years earlier led to a spike in fines in 2020 and 2021, the report argues the less dollar signs in agency coffers doesn’t mean less enforcement actions.
