Cartel Investigations Recruiters

Hiring starts when an inspection date is already in the diary, or when a published decision has turned into a damages inventory. A general counsel who staffs only for merger notifications is staffing a different desk. The European Commission’s cartel statistics, last changed on 15 December 2025, record cartel fines of EUR 859.5 million in 2025 and EUR 48.7 million in 2024. Those figures are not adjusted for later court judgments. They count Article 101 cartel infringements only. The same tables record 4 cartel decisions in 2025 against 1 in 2024, and 27 undertakings or associations in the 2025 decisions against 2 in 2024. The undertaking count includes parties that were not fined, including immunity applicants. It counts a corporate group as one undertaking. It does not include undertakings fined only for obstruction or for a breach of procedural duties. Those procedural amounts sit outside the fine totals as well: an additional EUR 15.9 million for obstruction in 2024, and an additional EUR 172,000 for a procedural breach in 2025.

The Commission’s staff working document of 5 May 2026, SWD(2026) 125, names the 2025 cartel decisions. On 1 April 2025 the Commission imposed fines of approximately EUR 458 million on 15 major car manufacturers and the European Automobiles Manufacturers’ Association (ACEA) for a cartel on end-of-life vehicle recycling, and described it as the largest cartel settlement so far by number of addressees. On 2 June 2025 it fined Delivery Hero and Glovo a total of EUR 329 million in online food delivery. Executive Vice-President Ribera’s statement the same day called it the first Commission fine for a no-poach agreement, and the first decision on the misuse of a minority shareholding to collude. The infringement ran from July 2018 to July 2022 and covered the European Economic Area. On 4 July 2025 the Commission fined Alchem EUR 489,000 for a cartel in a pharmaceutical ingredient lasting more than 12 years. On 15 December 2025 it fined automotive starter-battery manufacturers and the trade association Eurobat around EUR 72 million for price fixing. That is four decisions, across vehicles, food delivery, a pharmaceutical ingredient, and starter batteries, plus one labor-market theory inside the food-delivery decision. A recruiter who treats “antitrust associate” as one pool will send the raid lawyer, the damages lawyer, and the filing lawyer as if they were interchangeable.

The same product can produce two decisions on the same day. The Commission’s vehicle-recycling decision and the UK Competition and Markets Authority’s parallel case both landed on 1 April 2025. The CMA’s Annual Report and Accounts 2024 to 2025 records that the parties agreed, and paid, penalties totalling £77.69 million. Earlier in the same reporting year, on 21 February 2025, the CMA issued five infringement decisions on UK government bonds. Four banks settled and agreed to pay fines totalling £104.46 million. One bank alerted the CMA under the leniency policy and received immunity. A company that sells into both the European Economic Area and the United Kingdom is not hiring one jurisdiction’s counsel and hoping the other file stays quiet. In April 2025 the CMA also opened a consultation on updated leniency guidance. Counsel whose last marker was filed under the prior text are not automatically current.

In the United States the charging count and the fine count moved in opposite directions, and they must not be added together. The Antitrust Division’s criminal-cases page, updated 9 December 2025, lists 27 criminal cases filed in fiscal year 2025 and 20 in fiscal year 2024. The fines-and-penalties page, updated the same day, lists USD 6 million imposed in fiscal 2025 and USD 10.6 million in fiscal 2024. Fiscal 2025 on that summary page is total criminal cases. It is not a Sherman Act section 1 split. The Division’s workload statistics for fiscal years 2015 through 2024 do split the earlier year: of 20 criminal cases filed in fiscal 2024, 18 were Sherman Act section 1 cases. A hiring plan that reads “27 cartel indictments” into the fiscal 2025 line is reading a column the Division has not published. A hiring plan that reads the USD 6 million as a collapse in investigations is reading fines imposed by courts in that fiscal year, which often punish conduct charged earlier. The seat being filled is the lawyer who can staff a grand jury, a leniency proffer, or a corporate plea, not the lawyer who collects the judgment.

Australia shows how long the defense continues after the conduct ends. The ACCC’s media release of 29 August 2025 reported that the Full Federal Court had dismissed the appeals, so a penalty of AUD 57.5 million against BlueScope remains in place. The same release called that sum the highest penalty ordered for a competition-law breach. The underlying conduct was in 2013 and 2014. Liability was found in December 2022. The penalty was ordered in August 2023. The appeal closed in August 2025. A general counsel who waits for the appeal judgment before hiring investigation counsel has already spent the years when the defense was being built. Civil penalty litigation of that length is a reason the in-house seat and the outside team are both standing instructions, not a one-week raid project.

Merger control is the filing calendar: Hart-Scott-Rodino in the United States, EU concentration notifications, and the national forms that travel with a signed deal. Cartel investigations are the conduct file: inspections, leniency, settlements, and the criminal or civil case that follows. Antitrust litigation is the courtroom file after liability is in dispute, including follow-on damages. A lawyer can have done all three over a career. A requisition that requires all three in the last five years, in one city, usually describes a person who does not exist at the salary on offer. What happens to the in-house seat when deal volume falls, and the conduct docket does not, is set out in antitrust and competition as a countercyclical practice. The investigations seat is the search described here.

Unfair-competition and consumer-protection work is a third neighbor, covered on the unfair competition page. It shares statutes and sometimes the same partner. It does not share the inspection and leniency record. A partner whose book is false-advertising trials is not a substitute for a partner who has managed a multi-jurisdictional leniency application, unless the matters say otherwise. We read the matters.

The parent practice remains antitrust and competition recruiting. City pages for the US markets where that hiring concentrates, including Washington, New York, and San Francisco, stay on the broader practice. Brussels and London are real hiring markets for this work. A mandate in either city is run against the lawyers who actually practice there, not against a US-only list, and it does not depend on a separate city URL.

Company searches are retained only. The fee is 25–30% of the hire’s total first-year compensation. The retainer is 30% of the fee, paid at engagement and kept if the client cancels. Offer acceptance across placements is 96%. Replacement cover is 12 months on a retained general counsel, chief legal officer, or chief compliance officer search, and 6 months on other in-house searches. A head of cartel defense falls in the second category unless the role is in fact the GC, CLO, or CCO. Law-firm partner and counsel mandates are retained. The percentage above is the company schedule, not a second schedule invented for firms.

Across general counsel and chief legal officer searches since 2017, the shortlist arrives in 24 days and the median time to an accepted offer is 11 weeks, inside a range of 8 to 16 weeks. Those clocks are the GC and CLO book, part of 400+ placements since 2017 (230+ in-house). They are the wrong number to quote as the cartel average. Sartori & Partners has run 16 cartel-investigation searches since 2019. 10 were law-firm laterals, outside the in-house placement count. 6 were in-house investigation seats, inside the 400+ placements since 2017 (230+ in-house). The working screen for this specialty, separate from any regulator census, is 800+ counsel. That screen is a draft field, not the firm’s market map.

One completed company mandate shows the clock we actually used. A Frankfurt-listed chemicals group, after a dawn raid, hired its head of cartel defense in 13 weeks. The shortlist was 4 names, delivered on day 27. The general counsel later said, The shortlist named counsel who had sat a dawn raid and a leniency application. We hired the head of cartel defense from that list. The same 13 weeks, the same shortlist of 4, and the same day 27 are the figures for that mandate wherever it is described. They are not the 24-day and 11-week GC averages, and they are not a promise that the next chemicals file will match them.

The brief we will not run is a title plus a city. “Antitrust partner, Brussels, portable business” does not say whether the business is filings, raids, or trials. We ask for the last two inspections, the last leniency application, the jurisdictions on the cooperation agreement, and whether the candidate has been on the immunity side, the settling side, or the contested side. Conflicts are checked before anyone is approached. The client’s name stays off the first call. A candidate who is already counseling a co-cartelist is not put on the list to make the page look full.

For the candidate, the move is usually off-market. Investigation practices are small, and a partner’s clients notice a process that leaks. Nothing is sent to a company or a firm without written consent. A law-firm lateral is assessed on the matters that can actually move, the clients who cannot, and the team that would have to come with the partner. An in-house move is assessed on whether the person wants to stop being external counsel on the morning of the raid and start being the client. Those are different lives. We say so before a CV moves. Candidates who want a confidential conversation start at submitting a CV. Companies and firms that already have a seat to fill start at a client enquiry.