Cartel fines imposed by global antitrust enforcers—which are often viewed as a proxy for overall enforcement—continued to decline in 2025. The U.S. brought in only $6 million in cartel fines, one of the lowest totals in recent years and nearly $3 billion lower than the figure imposed a decade ago. Other jurisdictions, including Canada, Mexico, South Korea, Japan and India, also posted lower fine totals.
In 2026, enforcement figures are expected to remain subdued, driven by significant resource constraints—more than 4,000 staff departed the U.S. Department of Justice last year—and a shifting focus toward novel and inherently smaller domestic matters.
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What To Expect In 2026
Procurement Collusion and Domestic Markets
In 2025, there was enhanced attention paid by global enforcers on suspected cases of bid rigging in public procurement and we expect that trend to continue. In the U.S., President Trump’s “America First” agenda shifted enforcement back on domestic matters and away from international cartel matters.
Pocketbook Issues
Going hand in glove with the shift of global enforcers toward more domestic agendas, we also expect to see increased scrutiny this coming year of what U.S. enforcers have called “pocketbook issues,” like food stuffs, jobs, housing, healthcare, transportation and financing.
Artificial Intelligence
Enforcers also prioritized investigations into emerging technologies and particularly the use of AI to facilitate information exchanges. Heading into 2026, we expect enforcers to continue to emphasize the competition risks raised by emerging technologies.
The Marketplace of Ideas
Given the anticipated intensity of the political environment heading into the mid-term elections in the U.S., we expect U.S. enforcers to intensify their interest in pursuing antitrust theories in the marketplace of ideas.