Compliance Radar

Who was sanctioned, and for what?

Fines, court rulings and incidents from Europe, North America, Latin America, Asia-Pacific, Middle East and Africa: 2,207 cases from 44 jurisdictions, each with an official source and checked against that source before publication. Filter by country, area of law and sector. Click a chart to drill down one level.

20cases from 12 jurisdictions
€951.5mTotal of monetary amounts (18 cases with an amount)
€462.6mLargest single case: Teva Pharmaceutical Industries (Teva-Gruppe)
€8.7mMedian per case with an amount

Click a bar to drill down one level.

When?

per year, by date of decision
Trend
PeriodCasesTotal
20224€170.5m
20233€220.7m
20244€487.4m
20258€72.9m
20261–

20 cases

14 Aug 2026 Henkel AG & Co. KGaAHenkel/Liquid Nails: court blocks takeover of Loctite’s main competitor USAMerger control Order

Henkel wanted to buy the construction adhesive brand Liquid Nails for 725 million USD from the financial investor American Industrial Partners, thereby taking over the main competitor of its Loctite brand. After a seven-day trial, the federal court, on application by the Federal Trade Commission (FTC), issued a permanent injunction against the acquisition.

What organisations can take from it

Acquiring the closest competitor carries a high risk of prohibition, even at a moderate deal volume.

Authority / court
U.S. District Court for the Southern District of New York (auf Antrag der FTC)
Area of law
Competition law · Merger control
Legal basis
Section 7 Clayton Act; Section 13(b) FTC Act (Permanent Injunction)
Action
Order
Status of proceedings
unknown
Sector
Chemicals and pharmaceuticals
Employees
10,000 or more
Published
17 Aug 2026

Checked against the official source on 25 Sep 2026 · Direct link

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25 Jul 2025 Tamro Eesti OÜTamro Eesti: order against unfair payment terms for food supplements EstoniaAbuse of market power Order

In consignment agreements, the pharmaceutical wholesaler had made payment to suppliers of food supplements dependent on subsequent resale (payment period over 30 days) and had reserved the right to hold suppliers liable for spoiled goods. The Konkurentsiamet (Estonian Competition Authority) found infringements of the act on unfair trading practices in the food supply chain and ordered amended contractual terms.

What organisations can take from it

Purchasing terms in the food sector – including for food supplements – must comply with the 30-day payment period and the prohibition on shifting risk.

Authority / court
Konkurentsiamet (Estnische Wettbewerbsbehörde)
Area of law
Competition law · Abuse of market power
Legal basis
§ 4 Abs. 1 und 2, § 5 Abs. 2, § 7 Abs. 1 PTEKS (UTP-Richtlinie (EU) 2019/633)
Action
Order
Status of proceedings
unknown
Sector
Chemicals and pharmaceuticals

Checked against the official source on 25 Sep 2026 · Direct link

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4 Jul 2025 Alchem International Pvt. Ltd. und Alchem International (H.K.) LimitedAlchem: €489,000 fine for taking part in the SNBB pharmaceutical ingredient cartel EU levelCartels and collusion €489,000

According to the European Commission's findings, Alchem took part from 1 November 2005 to 12 February 2018 in an EEA-wide cartel concerning the active ingredient N-butylbromide scopolamine (SNBB), involving minimum prices, quotas and exchanges of sensitive information. Unlike the other participants, who were subject to a settlement decision in October 2023, Alchem declined to settle and received a fine of 489,000 EUR without any reduction.

What organisations can take from it

Suppliers of active pharmaceutical ingredients are also subject to the cartel prohibition; those who do not cooperate forgo reductions.

Relevance to training and awareness

Price-fixing and quota agreements between competitors

Authority / court
Europäische Kommission
Area of law
Competition law · Cartels and collusion
Legal basis
Art. 101 AEUV; Art. 53 EWR-Abkommen
Action
Fine
Status of proceedings
unknown
Sector
Chemicals and pharmaceuticals
Published
4 Jul 2025

Checked against the official source on 28 Sep 2026 · Direct link

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10 Jun 2025 Novamont S.p.A., Eni S.p.A.AGCM fines Novamont and Eni €32.1m over exclusivity ties in bioplastics ItalyAbuse of market power €32.1m

According to the AGCM, from at least January 2018 to December 2023 Novamont tied film producers to its bioplastic Mater-Bi through exclusive or semi-exclusive purchasing obligations and tied retail chains to carrier bags made by its licensees, thereby excluding competitors in bio-compounds for lightweight and very lightweight plastic carrier bags (Art. 102 TFEU). Novamont must pay 30,359,000 EUR (capped at the 10% turnover limit); for the period after its acquisition by the Eni group on 18 October 2023, Novamont and Eni are jointly and severally liable for a further 1,701,052.08 EUR, a total of 32,060,052.08 EUR.

What organisations can take from it

A compliance programme must address the specific competition risks of the business, such as exclusivity clauses used by a strong supplier, or it will not reduce the fine.

Relevance to training and awareness

Exclusivity clauses of dominant suppliers and effective compliance programmes

Missing or inadequate training played a role in the decision.

Authority / court
Autorità Garante della Concorrenza e del Mercato (AGCM)
Area of law
Competition law · Abuse of market power
Legal basis
Art. 102 AEUV; Art. 15 Legge n. 287/1990
Action
Fine
Status of proceedings
unknown
Sector
Chemicals and pharmaceuticals
Mitigating circumstances
None recognised: the compliance programme of the Eni group, which Novamont joined in October 2023, had not worked effectively because training and controls covered other topics and exclusive contracts continued to be concluded; the AGCM considered Novamont's earlier programme manifestly inadequate, partly because its competition law manual did not specifically address exclusive purchasing obligations among the forms of abuse.
Published
24 Jun 2025

Checked against the official source on 28 Sep 2026 · Direct link

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23 May 2025 Vifor Pharma UK Limited u. a. (CSL-Konzern)CMA: Vifor pays GBP 23m to the NHS after suspected disparagement of a rival United KingdomAbuse of market power €27.4m

The CMA had investigated whether, between 2010 and 2024, Vifor abused a suspected dominant position in high-dose intravenous iron by spreading potentially misleading claims about the safety of the rival product Monofer compared with its own Ferinject. It accepted binding commitments: a voluntary payment of GBP 23m to the NHS, a corrective communication campaign aimed at healthcare professionals and additional compliance measures; no infringement was found.

What organisations can take from it

Safety claims about competing products made to healthcare professionals must be substantiated and balanced – disparagement can be pursued as an abuse of market power.

Relevance to training and awareness

Claims about competitor products in pharmaceutical marketing

Authority / court
Competition and Markets Authority (CMA)
Area of law
Competition law · Abuse of market power
Legal basis
Chapter II prohibition, section 18(1) Competition Act 1998 (Verdacht); Verpflichtungszusagen nach section 31A Competition Act 1998
Action
Other
Status of proceedings
final
Sector
Chemicals and pharmaceuticals
Published
23 May 2025

Original amount 23,000,000 GBP, converted at the ECB reference rate of 23 May 2025.

Checked against the official source on 3 Oct 2026 · Direct link

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28 Apr 2025 Bayer S.A.Bayer pays 5 million BRL in CADE settlement over information exchange among employers BrazilCartels and collusion €773,398

Bayer S.A. concluded a settlement (Termo de Compromisso de Cessação) with the Conselho Administrativo de Defesa Econômica (CADE, Brazilian competition authority) in proceedings concerning the exchange of competitively sensitive information between employers in the consumer goods sector with possible effects on the Brazilian labour market. The company admitted its participation, undertook to cease the conduct and to cooperate with the investigation, and allegedly pays 5,003,188.80 BRL to the Fund for Diffuse Rights (FDD). In the same proceedings, 3M do Brasil concluded a separate settlement of allegedly 4,454,414.82 BRL. The amount and the facts have not been confirmed against the primary source.

What organisations can take from it

Exchanging sensitive HR and labour market information between competing employers also carries competition law risk.

Relevance to training and awareness

Competition law in HR: information exchange between employers

Authority / court
Conselho Administrativo de Defesa Econômica (CADE), Tribunal Administrativo
Area of law
Competition law · Cartels and collusion
Legal basis
Lei nº 12.529/2011 (Lei de Defesa da Concorrência), Termo de Compromisso de Cessação
Action
Other
Status of proceedings
final
Sector
Chemicals and pharmaceuticals
Employees
10,000 or more
Published
6 May 2025

Original amount 5,003,188.8 BRL, converted at the ECB reference rate of 28 Apr 2025.

Checked against the official source on 3 Oct 2026 · Direct link

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24 Apr 2025 Johnson & Johnson Consumer NV; Boehringer Ingelheim SComm; Haleon Belgium NVJohnson & Johnson, Boehringer, Haleon: 11.2 million EUR for shelf-placement collusion in pharmacies BelgiumCartels and collusion €11.2m

Over more than 15 years, the three OTC medicine manufacturers jointly developed the category management project ‘SMAN’, through which they steered the placement of non-prescription medicines in selected pharmacies in their favour and disadvantaged or excluded competing products. In a settlement procedure, the Autorité belge de la Concurrence / Belgische Mededingingsautoriteit (Belgian Competition Authority, BMA) imposed a total of 11,249,280.48 EUR.

What organisations can take from it

Category management agreements with retailers must not push competitors off the shelf – joint planograms with competitors are off limits.

Relevance to training and awareness

Competition law limits of category management

Authority / court
Autorité belge de la Concurrence / Belgische Mededingingsautoriteit (BMA)
Area of law
Competition law · Cartels and collusion
Legal basis
Code de droit économique Art. IV.1; AEUV Art. 101
Action
Fine
Status of proceedings
final
Sector
Chemicals and pharmaceuticals
Employees
10,000 or more
Published
24 Apr 2025

Checked against the official source on 25 Sep 2026 · Direct link

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10 Apr 2025 Boehringer Ingelheim, Alkaloids of Australia, C2 PHARMA u. a. (7 Unternehmen)WEKO sanctions active-ingredient cartel over butylscopolamine bromide at around CHF 600,000 SwitzerlandCartels and collusion €645,231

Between 2005 and 2019 Boehringer Ingelheim, Alkaloids of Australia, Alkaloids Corporation, Alchem, C2 PHARMA, Linnea and Transo-Pharm set minimum selling prices for the active ingredient butylscopolamine bromide (SNBB), allocated quotas and exchanged sensitive business information. The Wettbewerbskommission (WEKO, Swiss Competition Commission) closed the case with amicable settlements; sanctions total around CHF 600,000, with C2 PHARMA as the self-reporting party exempted in full and Transo-Pharm and Linnea in part. It is the first cartel concerning a pharmaceutical active ingredient that WEKO has sanctioned.

What organisations can take from it

Even small niche markets for intermediate products are watched by competition authorities, and the first to report can escape the sanction entirely.

Relevance to training and awareness

Cartel risks for intermediate products and active ingredients; leniency programme

Authority / court
Wettbewerbskommission (WEKO)
Area of law
Competition law · Cartels and collusion
Legal basis
Kartellgesetz (KG): Preis- und Mengenabrede, einvernehmliche Regelungen, Bonusregelung
Action
Fine
Status of proceedings
unknown
Sector
Chemicals and pharmaceuticals
Mitigating circumstances
Amicable settlements; full immunity for C2 PHARMA (leniency programme), partial reduction for Transo-Pharm and Linnea.
Published
10 Apr 2025

Original amount 600,000 CHF, converted at the ECB reference rate of 10 Apr 2025.

Checked against the official source on 2 Oct 2026 · Direct link

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8 Apr 2025 Pailpac (Pty) LtdAlleged abuse of dominance: Pailpac allegedly pays ZAR 5m and ends exclusive contracts South AfricaAbuse of market power €236,068

On 8 April 2025 the Competition Tribunal (South Africa's competition adjudicator) confirmed a settlement with Pailpac (Pty) Ltd, a maker of injection-moulded plastic pails for the paints and coatings industry. The Competition Commission (competition authority) alleged that, as the dominant supplier of containers for water-based coatings, the company had tied major customers through exclusive or near-exclusive supply agreements and used below-cost pricing; Pailpac disputes this. It nevertheless allegedly pays an administrative penalty of 5,000,000 ZAR, releases customers from exclusivity and automatic renewal clauses, will buy packaging waste from small businesses and informal waste collectors for five years and will introduce a compliance programme.

What organisations can take from it

Suppliers with strong market positions should have exclusivity and automatic renewal clauses checked under competition law before tying major customers to them.

Relevance to training and awareness

Exclusive contracts and below-cost pricing by dominant firms

Authority / court
Competition Tribunal of South Africa (auf Antrag der Competition Commission)
Area of law
Competition law · Abuse of market power
Legal basis
Section 8(1)(d)(i) und 8(1)(c) Competition Act 89 of 1998 (Vorwurf der Competition Commission, ohne Anerkenntnis)
Action
Fine
Status of proceedings
final
Sector
Chemicals and pharmaceuticals
Published
9 Apr 2025

Original amount 5,000,000 ZAR, converted at the ECB reference rate of 8 Apr 2025.

Checked against the official source on 4 Oct 2026 · Direct link

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11 Dec 2024 Hipolabor Farmacêutica Ltda., Sanval Comércio e Indústria Ltda., Comercial Cirúrgica Rioclarense Ltda. u. a. (5 Unternehmen)CADE: hub-and-spoke cartel in medicines – BRL 45.3m on five companies BrazilCartels and collusion €7.15m

The CADE Tribunal convicted five companies of a cartel in public tenders for medicines and in private pharmaceutical sales which, according to CADE, operated at least from 2007 to 2011 in states including Minas Gerais, São Paulo, Bahia and Pernambuco; besides direct price-fixing between manufacturers, some manufacturers facilitated collusion between distributors (hub-and-spoke cartel). The fines on the companies total 45,328,574.05 BRL (Hipolabor Farmacêutica 15,741,025.02; Sanval 12,191,091.60; Comercial Cirúrgica Rioclarense 11,952,437.72; Rhamis Distribuidora Farmacêutica 3,585,615.18; Macromed 1,858,404.53 BRL). Proceedings against several other parties were closed for lack of evidence or because settlements had been fulfilled. The amount and the facts have not been confirmed against the primary source.

What organisations can take from it

Manufacturers must neither organise nor facilitate price coordination between their distributors; acting as the "hub" is itself a cartel infringement.

Relevance to training and awareness

Hub-and-spoke collusion between manufacturers and distributors in tenders

Authority / court
Conselho Administrativo de Defesa Econômica (CADE), Tribunal Administrativo
Area of law
Competition law · Cartels and collusion
Legal basis
Art. 20 I–IV i. V. m. Art. 21 I, II, III, VIII Lei nº 8.884/1994, entsprechend Art. 36 I–IV, § 3 I a, c, d Lei nº 12.529/2011; Bemessung nach Art. 37 Lei nº 12.529/2011
Action
Fine
Status of proceedings
unknown
Sector
Chemicals and pharmaceuticals
Liability of senior managers
Measures against individuals are not set out here.
Published
12 Dec 2024

Original amount 45,328,574.05 BRL, converted at the ECB reference rate of 11 Dec 2024.

Checked against the official source on 3 Oct 2026 · Direct link

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22 Nov 2024 Viatris Inc.Viatris: 1.5 million GBP – key staff replaced despite hold-separate order United KingdomMerger control €1.8m

During the review of the sale of the European rights to the hormone products Duphaston and Femoston to Theramex, an Initial Enforcement Order was in force. Viatris replaced members of the UK management without the consent of the Competition and Markets Authority (CMA) and subsequently failed to report the breach; the CMA imposed 1.5 million GBP.

What organisations can take from it

During a merger review, staffing decisions in the target business also require consent – and breaches must be reported immediately.

Relevance to training and awareness

Standstill and interim obligations in merger proceedings (management, HR)

Authority / court
Competition and Markets Authority (CMA)
Area of law
Competition law · Merger control
Legal basis
Enterprise Act 2002, s. 72(2) (Initial Enforcement Order), s. 94A
Action
Fine
Status of proceedings
unknown
Sector
Chemicals and pharmaceuticals
Employees
10,000 or more

Original amount 1,500,000 GBP, converted at the ECB reference rate of 22 Nov 2024.

Checked against the official source on 28 Sep 2026 · Version 2 · Direct link

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31 Oct 2024 Teva Pharmaceutical Industries (Teva-Gruppe)EU: 462.6 million EUR against Teva for patent misuse and disparaging a competing medicine EU levelAbuse of market power €462.6m

Teva abused its dominant position for the MS medicine Copaxone: it artificially extended patent protection by filing staggered divisional applications with the EPO and strategically withdrawing them, and spread misleading statements about an authorised competing product among physicians and decision-makers. Seven Member States were affected over periods of four to nine years.

What organisations can take from it

Communications by sales representatives and medical affairs about competing products must be substantiated and objective; patent strategies of dominant companies require competition law review.

Relevance to training and awareness

Disparaging statements about competing products to healthcare professionals

Authority / court
Europäische Kommission
Area of law
Competition law · Abuse of market power
Legal basis
Art. 102 AEUV
Action
Fine
Status of proceedings
unknown
Sector
Chemicals and pharmaceuticals
Employees
10,000 or more

Checked against the official source on 28 Sep 2026 · Version 2 · Direct link

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24 Jun 2024 a US flavours and fragrances manufacturer and its French subsidiaryFragrance manufacturer: €15.9m fine for deleting WhatsApp messages during an inspection EU levelCompetition lawanonymised €15.9m

During a European Commission inspection in the fragrance sector in March 2023, a senior employee of the manufacturer, after being informed of the inspection, deleted WhatsApp messages exchanged with a competitor on a mobile phone; the Commission treated this as obstruction of the inspection. It is the Commission's first fine for deleting messages in a messaging app; because of the manufacturer's cooperation, the amount was reduced by 50% to €15.9m (0.15% of total turnover).

What organisations can take from it

During regulatory inspections, companies must immediately ensure that nobody deletes data on work phones or in messaging apps.

Relevance to training and awareness

Conduct during dawn raids and preservation of evidence in messaging apps

Authority / court
Europäische Kommission
Area of law
Competition law
Legal basis
Verordnung (EG) Nr. 1/2003 (Behinderung einer Nachprüfung)
Action
Fine
Status of proceedings
unknown
Sector
Chemicals and pharmaceuticals
Culpability
intentional
Mitigating circumstances
Immediate acknowledgement, proactive cooperation and help in recovering the data: 50% reduction.
Liability of senior managers
The deletion was carried out by a senior employee; the fine is addressed to the companies.
Published
24 Jun 2024

Checked against the official source on 28 Sep 2026 · Company name anonymised since 24 Jun 2026 · Direct link

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20 Dec 2023 a Portuguese supplier of food supplements and health productsPortugal: €1.04m for health products supplier over imposed resale prices PortugalCartels and collusionanonymised €1.04m

The competition authority fined the supplier of food supplements and health products 1,040,000 EUR because between 2016 and 2022 it prescribed retail prices and discount limits to distributors, monitored them and responded to deviations with cuts in terms or supply restrictions. The decision is not final.

What organisations can take from it

Suppliers should rule out price instructions to distributors and their monitoring, both in contracts and in practice.

Relevance to training and awareness

Resale price maintenance

Authority / court
Autoridade da Concorrência (AdC)
Area of law
Competition law · Cartels and collusion
Legal basis
Art. 9 Lei n.º 19/2012 (Lei da Concorrência); Art. 101 AEUV
Action
Fine
Status of proceedings
under appeal
Sector
Chemicals and pharmaceuticals
Published
29 Dec 2023

Checked against the official source on 28 Sep 2026 · Company name anonymised since 20 Dec 2025 · Direct link

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19 Oct 2023 six manufacturers and traders of an active pharmaceutical ingredientEU: 13.4 million EUR against pharmaceutical ingredient cartel (SNBB) EU levelCartels and collusionanonymised €13.4m

From 2005 to 2019, six manufacturers and traders of the active ingredient SNBB (the base substance for a branded medicine and generics) fixed minimum prices, allocated quotas and exchanged sensitive information. This was the first cartel concerning an active pharmaceutical ingredient that the Commission has sanctioned; the leniency applicant received full immunity, and all parties reached a settlement.

What organisations can take from it

Even small niche markets for active ingredients are in the spotlight – contacts with competitors about prices or volumes are off-limits.

Relevance to training and awareness

Price and quota agreements in the trade in active ingredients

Authority / court
Europäische Kommission
Area of law
Competition law · Cartels and collusion
Legal basis
Art. 101 AEUV, Art. 53 EWR-Abkommen
Action
Fine
Status of proceedings
unknown
Sector
Chemicals and pharmaceuticals
Mitigating circumstances
Leniency programme (leniency applicant 100 %, a second company 50 %, a third 30 %), 10 % settlement reduction

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 19 Oct 2025 · Direct link

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21 Aug 2023 a US generic drug manufacturerDOJ: generics manufacturer pays 225 million USD criminal penalty over generic drug price fixing USACartels and collusionanonymised €206.3m

In a Deferred Prosecution Agreement, the manufacturer admitted to three conspiracies involving price fixing, customer allocation and bid rigging for generic drugs (including pravastatin). The manufacturer is paying a criminal penalty of 225 million USD in instalments, donating medicines worth 50 million USD and must divest its pravastatin business under the supervision of a monitor.

What organisations can take from it

In addition to penalties running into millions, antitrust violations can force companies to divest entire product lines.

Relevance to training and awareness

Agreements among generic drug manufacturers on prices and customers

Authority / court
U.S. Department of Justice, Antitrust Division
Area of law
Competition law · Cartels and collusion
Legal basis
15 U.S.C. § 1 (Sherman Act)
Action
Fine
Status of proceedings
unknown
Sector
Chemicals and pharmaceuticals
Employees
10,000 or more

Original amount 225,000,000 USD, converted at the ECB reference rate of 21 Aug 2023.

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 21 Aug 2025 · Direct link

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29 Nov 2022 six purchasers of styrene monomerEU: 157 million EUR against purchasing cartel for styrene monomer EU levelCartels and collusionanonymised €157.1m

From 2012 to 2018, six purchasers of styrene coordinated their negotiating strategy for the industry reference price (SMCP) and exchanged price information in order to push down the purchase price. The Commission imposed fines totalling 157 million EUR, including 32.505 million EUR on one company and 31.72 million EUR on another; the leniency applicant escaped a fine.

What organisations can take from it

Not only selling but also purchasing agreements are prohibited – buyers need competition law training just as much as sales staff.

Relevance to training and awareness

Purchasing cartel: coordination of negotiating strategies among buyers

Authority / court
Europäische Kommission
Area of law
Competition law · Cartels and collusion
Legal basis
Art. 101 AEUV, Art. 53 EWR-Abkommen
Action
Fine
Status of proceedings
unknown
Sector
Chemicals and pharmaceuticals
Mitigating circumstances
Leniency programme for almost all parties, 10 % settlement reduction

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 29 Nov 2024 · Direct link

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15 Nov 2022 a Portuguese food supplement supplierPortugal: €1.26m for food supplement supplier over resale price maintenance PortugalCartels and collusionanonymised €1.26m

The competition authority fined the food supplement supplier 1,258,900 EUR because, from October 2015 to January 2022, it dictated retail prices and maximum discounts to distributors, monitored compliance and punished deviations with worse terms or supply cuts. The fine was reduced by 30% in the settlement procedure.

What organisations can take from it

Recommended prices become prohibited resale price maintenance once compliance is monitored and deviations are punished.

Relevance to training and awareness

Resale price maintenance

Authority / court
Autoridade da Concorrência (AdC)
Area of law
Competition law · Cartels and collusion
Legal basis
Art. 9 Lei n.º 19/2012 (Lei da Concorrência); Art. 101 AEUV
Action
Fine
Status of proceedings
unknown
Sector
Chemicals and pharmaceuticals
Mitigating circumstances
Settlement procedure (transação), practice ended; 30% reduction.
Published
19 Dec 2022

Checked against the official source on 28 Sep 2026 · Company name anonymised since 15 Nov 2024 · Direct link

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10 Nov 2022 three companies of an international pharmaceutical groupCNMC: €10.25m fine on pharmaceutical group for excessive pricing of an orphan medicine SpainAbuse of market poweranonymised €10.3m

The Comisión Nacional de los Mercados y la Competencia (CNMC, Spanish competition and markets authority) imposed a fine of 10,250,000 EUR, for which three companies of the pharmaceutical group are jointly and severally liable, because as the sole supplier of CDCA medicines for the rare metabolic disease cerebrotendinous xanthomatosis they abused their dominant position and charged the Spanish national health system an excessive price. In addition, the group must waive the exclusivity agreed with the only supplier of the active ingredient and market the product directly in Spain.

What organisations can take from it

A sole supplier of an indispensable medicine must be able to justify price increases objectively and must not cut competitors off from the active ingredient through exclusive supply agreements.

Relevance to training and awareness

Pricing by dominant undertakings (excessive prices)

Authority / court
Comisión Nacional de los Mercados y la Competencia (CNMC)
Area of law
Competition law · Abuse of market power
Legal basis
Art. 2 Ley 15/2007 de Defensa de la Competencia; Art. 102 AEUV
Action
Fine
Status of proceedings
unknown
Sector
Chemicals and pharmaceuticals
Published
14 Nov 2022

Checked against the official source on 28 Sep 2026 · Company name anonymised since 10 Nov 2024 · Direct link

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13 Oct 2022 five pharmaceutical companiesPay-for-delay in cancer drugs: KFTC sanctions originator and generic manufacturers South KoreaCartels and collusionanonymised €1.9m

The Korea Fair Trade Commission (KFTC, Korea's competition authority) objected to an agreement concluded at the end of September 2016 under which the generics side undertook not to manufacture or launch generic versions of three cancer drugs in Korea from October 2016 to December 2020, receiving in return exclusive distribution rights for these originator products from the originator side; according to the KFTC, the arrangement was terminated early on 12 January 2018. It issued cease-and-desist orders against all five companies (two on the originator side, including its Korean company, and three on the generics side, including its Korean company) and provisionally set fines totalling KRW 2,645 million: KRW 1,146 million for the originator side and KRW 1,499 million for the generics side.

What organisations can take from it

Distribution or licensing agreements with a potential generic manufacturer must not contain a clause that rules out its own market entry.

Relevance to training and awareness

Agreements with potential competitors to refrain from market entry (pay-for-delay)

Authority / court
Korea Fair Trade Commission (KFTC)
Area of law
Competition law · Cartels and collusion
Legal basis
Art. 19 Abs. 1 Nr. 3 MRFTA a. F. (Monopoly Regulation and Fair Trade Act; heute Art. 40 Abs. 1 Nr. 3)
Action
Fine
Status of proceedings
unknown
Sector
Chemicals and pharmaceuticals
Published
13 Oct 2022

Original amount 2,645,000,000 KRW, converted at the ECB reference rate of 13 Oct 2022.

Checked against the official source on 8 Oct 2026 · Company name anonymised since 13 Oct 2024 · Direct link

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