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  • 1.

    What is the general attitude of business and the authorities to competition compliance?

  • 2.

    Is there a government-approved standard for compliance programmes in your jurisdiction?

  • 3.

    Is the compliance guidance generally applicable or do best practice and obligations depend on company size and the sector of the economy in which it operates?

  • 4.

    If the company has a competition compliance programme in place, does it have any effect on sanctions?

  • 5.

    How does a company demonstrate its commitment to competition compliance?

  • 6.

    What are the key features of a compliance programme regarding risk identification?

  • 7.

    What are the key features of a compliance programme regarding risk-assessment?

  • 8.

    What are the key features of a compliance programme regarding risk-mitigation?

  • 9.

    What are the key features of a compliance programme regarding review?

  • 10.

    What types of arrangements should the company avoid entering into with its competitors?

  • 11.

    What precautions can be taken to manage competition law risk when the company enters into an arrangement with a competitor?

  • 12.

    What form must behaviour take to constitute a cartel?

  • 13.

    Under what circumstances can cartels be exempted from sanctions?

  • 14.

    Can the company exchange information with its competitors?

  • 15.

    Is a leniency programme available to companies or individuals who participate in a cartel in your jurisdiction?

  • 16.

    Can the company apply for leniency for itself and its individual officers and employees?

  • 17.

    Can the company reserve a place in line before a formal leniency application is ready?

  • 18.

    If the company blows the whistle on other cartels, can it get any benefit?

  • 19.

    What types of vertical arrangements between the company and its suppliers or customers are subject to competition enforcement?

  • 20.

    Would the regulatory authority consider the above vertical arrangements per se illegal? If not, how do they analyse and decide on these arrangements?

  • 21.

    Under what circumstances can vertical arrangements be exempted from sanctions?

  • 22.

    Which factors does your jurisdiction apply to determine if the company holds a dominant market position?

  • 23.

    If the company holds a dominant market position, what forms of behaviour constitute abuse of market dominance? Describe any recent cases.

  • 24.

    Under what circumstances can abusing market dominance be exempted from sanctions or excluded from enforcement?

  • 25.

    Does the company need to obtain approval from the competition authority for mergers and acquisitions? Is it mandatory or voluntary to obtain approval before completion?

  • 26.

    How long does it normally take to obtain approval?

  • 27.

    If the company obtains approval, does it mean the authority has confirmed the terms in the documents will be considered compliant with competition law?

  • 28.

    What are the consequences for failure to file, delay in filing and incomplete filing? Have there been any recent cases?

  • 29.

    Under which circumstances would the company and officers or employees need separate legal representation? Do the authorities require separate legal representation during certain types of investigations?

  • 30.

    For what types of infringement would the regulatory authority launch a dawn raid? Are there any specific procedural rules for dawn raids?

  • 31.

    What are the company’s rights and obligations during a dawn raid?

  • 32.

    Is there any mechanism to settle, or to make commitments to regulators, during an investigation?

  • 33.

    What weight will the authorities place on companies implementing or amending a compliance programme in settlement negotiations?

  • 34.

    Are corporate monitorships used in your jurisdiction?

  • 35.

    Are agreed statements of facts in a settlement with the authorities automatically admissible as evidence in actions for private damages, including class-actions or representative claims?

  • 36.

    Can the company or an individual invoke legal privilege or privilege against self-incrimination in an investigation?

  • 37.

    What confidentiality protection is afforded to the company and/or individual involved in competition investigations?

  • 38.

    What are the penalties for refusing to cooperate with the authorities in an investigation?

  • 39.

    Is there a duty to notify the regulator of competition infringements?

  • 40.

    What are the limitation periods for competition infringements?

  • 41.

    Are there any other regulated anticompetitive practices not mentioned above? Provide details.

  • 42.

    Are there any proposals for competition law reform in your jurisdiction? If yes, what effects will it have on the company’s compliance?

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ACTECON provides high-level, unique and specialised service to clients mainly in the areas of competition law, mergers & acquisitions, regulation and international trade. The firm’s principles include international work ethic, commitment to provide value-adding service and consistency in every aspect.

View more information about ACTECON

Francalaci Sok No. 28
Arnavutköy, Beşiktaş 34345
T: +90 212 211 50 11
F: +90 212 211 32 22


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