In this contribution, the authors, Anne Riley, former Head of Royal Dutch Shell’s global antitrust group, and Paul Lugard, (Baker Botts (Belgium) LLP, provide a tour d’horizon of antitrust compliance-related topics. Drawing on their decades-long experience as, respectively, inhouse antitrust counsel and private practitioner, the authors discuss ten key points for both competition enforcement agencies and compliance professionals to consider. In addition, they provide valuable insights into antitrust compliance-related work of the OECD, the International Competition Network and the International Chamber of Commerce. But above all, this contribution seeks to provide practical insights and suggestions on how to optimize the use of antitrust compliance programmes.

By Paul Lugard & Anne Riley[1]



In many respects, competition law compliance remains an important and topical issue, both for companies and competition enforcement agencies. Importantly, the area of competition law compliance is also highly dynamic. Indeed, while the foundations for successful and credible compliance programs in many areas of law outside antitrust have become almost universally accepted in the last two decades, antitrust compliance programs are not being so widely accepted yet. But the world has moved on, and antitrust needs to catch up.

For one thing, over the past decade, successful implementation of compliance programs has become more sophisticated an


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