Criminal Antitrust Defense and Investigations

Criminal Antitrust Defense and Investigations

The past decade has seen an explosion in criminal antitrust enforcement activity by antitrust enforcement agencies around the globe, and a dramatic increase in the legal risk facing multinational businesses with exposure to accusations of involvement in price fixing, customer or market allocation, and other types of "cartel conduct."

Antitrust enforcers in the United States, Europe, and Asia increasingly agree that prosecuting cartel and price-fixing activity is a top priority. More and more jurisdictions have adopted amnesty programs that offer great potential benefits to companies that discover wrongdoing in their ranks, but dangerous pitfalls for counsel who lack the most up-to-date information. Firms with worldwide businesses, therefore, have exposure to enforcement actions by multiple jurisdictions in the event of a cartel investigation. If not in a position to exonerate themselves, such firms may end up having to pay fines in the United States, Europe, and other jurisdictions.

The Hunton & Williams LLP criminal antitrust defense practice is led on the U.S. side by Ray Hartwell, who is listed in the Global Competition Review Who's Who of competition lawyers for his cartel enforcement experience. Hartwell — former managing partner of the firm's Brussels office — has decades of experience representing corporations in criminal antitrust matters in the U.S. and abroad. He is well known for his representation of high-ranking corporate officials who need separate legal counsel. The group also includes David Higbee, a principal architect of the Department of Justice’s recent criminal antitrust enforcement activities. 

In criminal competition matters, the group has successfully represented companies in defending against indictment, and also has represented companies seeking protection under amnesty programs in the U.S. and Canada, and in European and Asian jurisdictions. In the European Union, we have extensive experience advising at all stages of the administrative proceedings (from the dawn raid, through the investigation, the preparation of leniency applications, the reply to the Statement of Objections and the oral hearing) until the adoption of a decision, and thereafter in the preparation and representation of court litigation.

Furthermore, our practice combining private practice and government experience allows us to organize highly relevant compliance programs. Compliance programs (including internal audits) and advice on ongoing investigations are performed in cooperation with our top-ranked privacy practice to ensure compliance with applicable data protection and privacy rules.

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