When deal volume falls, does the company still need the seat?

Dawn raids are a measured, continuing stream. The Commission’s 2025 board records three unannounced antitrust inspections — vaccines, non-alcoholic drinks, ski equipment — plus one Foreign Subsidies Regulation inspection at an e-commerce company. Belgium is not a blank on that map. The Belgian Competition Authority rewrote its own raid playbook on 20 June 2025: investigators may start immediately; waiting for a lawyer is not a validity condition; private devices used even partly for work are in scope; a ten-working-day window follows for privilege and out-of-scope lists. The in-house competition seat is the person who has already walked reception and IT through that script. Cutting the seat in a quiet quarter means the first person through the door is an external avocat who has never seen the share drive.

Follow-on damages are a multi-year inventory, not a filing-year product. Jean-François Laborde’s 2025 Concurrences compilation identified 444 cartel damages actions across 30 European countries, with 115 damages awarded, 73 liability findings, 215 dismissals and 41 still pending. Awards include France 34, Spain 23, Germany 19, Belgium 2 and the United Kingdom 3. Overcharge rates calculated for 110 awards ran from less than 1 percent to 34 percent. After every national cartel or abuse decision, the defendant group needs an in-house competition and litigation counsel who can run that book — and a claimant-side commercial counsel who can open one. That is the opposite of a seat a chief legal officer stands down because notifications dipped.

Two residual rules keep a closed deal on the same desk. In Towercast (C-449/21, 16 March 2023) the Court of Justice left a below-threshold concentration open to Article 102 review; the Belgian authority applied that case law in 2025. The Illumina/Grail judgment of 3 September 2024 closed one below-threshold referral path. It did not close the in-house risk. Residual risk sat down in Article 102, in national call-in powers where they exist, and in the foreign-subsidy call-in. A general counsel who reads a jurisdictional loss as a demand loss is reading the wrong document.

On 3 September 2026 the Commission adopted the first Guidelines on exclusionary abuses of dominance under Article 102 TFEU and withdrew the 2009 enforcement priorities. Dominant firms are told to test dominance, then exclusionary effects, then any objective justification. Every group a general counsel would describe as having market share worth defending now has a board-level rewrite on pricing, rebates, refusal-to-supply, tying and self-preferencing. That rewrite is this seat. It is not a seconded deal lawyer.

Washington keeps a criminal labor file that does not move with premerger volume. A federal jury convicted a home-health executive of a Sherman Act wage-fixing conspiracy on 14 April 2025; on 21 November 2025 the district court imposed 40 months’ custody, a USD 550,000 criminal fine, USD 2,496,101 in restitution and forfeiture of about USD 10.459 million. The Antitrust Division called wage-fixing a nakedly unlawful agreement crime and said such conduct will not be resolved with a fine. A US group’s in-house competition counsel — wherever the chief legal officer sits — now owns no-poach and wage-benchmarking with HR. The same labor file the Commission opened in Europe in June 2025.

Of the six competition-primary seats inside Sartori’s 15 closed Brussels in-house searches over three years, three completed inside the four-to-seven-month envelope. Two ran past seven months because the buyer specified a ten-year agency-plus-firm profile the local pool would not release without a fight. One of the six was withdrawn after a first shortlist that was filing-heavy: the chief legal officer had written a notifications brief for a dominance and digital seat. That is the finding that does not flatter the desk. The Brussels in-house line still carries a 27 percent counter-offer incidence; the median offer-to-acceptance window is the 13 working days already on the grid above. We cannot see, and this page does not invent, a census of in-house competition seats in Brussels, London or Washington.

Three composites, presented as Sartori engagements, show the same arithmetic from the buyer’s side. A Belgian-established consumer-goods group with a four-lawyer global competition cell asked us, in a quarter with no live notification, whether the Senior Legal Counsel (Competition) seat could be frozen. The brief that survived named supplier follow-on claims and a verticals rewrite. The search closed in five months. A US-listed semiconductor issuer hired a Belgium-remote Senior Competition Counsel against a twelve-year gate to interface with the Commission and national authorities; the live posting said so in those words. A listed chemicals group tried for eight weeks to cover a foreign-subsidy questionnaire from corporate counsel and came back with a rebuilt brief for a Lead Competition, Trade and FDI seat. None of those files was a filing-year product.

A company that has decided the seat is real can start from the Washington competition associate search, the Washington competition associate salary page, the dated Brussels general-counsel cash table on general counsel salary in Brussels 2026, or a confidential Brussels brief through the in-house desk. How we underwrite a search is on the methodology page. The officer who decides whether the seat stays open is the subject of what companies look for in a new general counsel.