Compliance Programs and Swiss Cartel Act: From Training to Operation Controls and Enforcement Mechanisms

Pranvera Këllezi Published 25 May 2025 The Swiss Federal Court has confirmed the Competition Commission’s longstanding position refusing to recognize compliance programs as mitigating factors in reducing fines (case 2C_442/2023, April 14, 2025). The court clearly held that compliance programs never have an exculpatory effect. However, the ruling clarifies the conditions under which compliance programs […]

Compliance Programs and Swiss Cartel Act: From Training to Operation Controls and Enforcement Mechanisms

Pranvera Këllezi Published 25 May 2025 The Swiss Federal Court has confirmed the Competition Commission’s longstanding position refusing to recognize compliance programs as mitigating factors in reducing fines (case 2C_442/2023, April 14, 2025). The court clearly held that compliance programs never have an exculpatory effect. However, the ruling clarifies the conditions under which compliance programs […]