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Date Posted: 02:56:43 08/03/06 Thu
Author: PUBLICATIONS
Subject: EXTRATERRITORIAL ENFORCEMENT OF THE UNITED STATES ANTITRUST LAWS
In reply to: Week of 7 to 11 July 2003 's message, "PROCEEDINGS OF THE COURT OF JUSTICE AND THE COURT OF FIRST INSTANCE OF THE EUROPEAN COMMUNITIES" on 02:35:02 08/03/06 Thu

PUBLICATIONS




EXTRATERRITORIAL ENFORCEMENT OF THE UNITED STATES ANTITRUST LAWS
7/12/2000

(Rapidly Increasing Risks Of Significant Fines And Jail Terms Being
Imposed Against International Cartels)
by Steven L. Katz, Jerrold E. Fink and Yoshiaki Tsuchitani
I. Introduction
For those who like risks, there is a new form of gambling. The stakes are very high, especially for the losers. The casinos are not in Las Vegas or in Monaco. They are in hotels and in corporate boardrooms and offices throughout the world. The dealer is the Antitrust Division of the United States Department of Justice. The house rules have changed and the dealer is winning more money, longer jail terms, and more often than before.

The reach of the United States criminal antitrust laws has now extended far beyond the borders of the United States and has crossed the oceans into Tokyo, Basel, Switzerland, and Wisebaden, Germany -- and elsewhere throughout the world. The U.S. antitrust laws are being applied to activities once thought to be beyond the jurisdiction of the United States antitrust enforcement agencies. The costs of becoming ensnared, through international cartels or other international conduct which arguably violates the United States antitrust laws, has increased dramatically during the past several years and seems to be accelerating at a increasingly unabated pace.

Encouraged by court rulings and a political atmosphere which supports aggressive enforcement of the antitrust laws, officials of the Antitrust Division of the United States Department of Justice (the "DOJ") and, to a lesser extent, the United States Federal Trade Commission (the "FTC"), have clearly signaled increased vigilance and criminal enforcement against international agreements which have, or might have, adverse competitive impacts within the United States-- even where the activities or agreements involve non-U.S. companies and occur primarily, or even exclusively, outside the United States. Criminal convictions for violating U.S. antitrust laws in such areas as price fixing, production/output limits, and market/customer allocations are not only increasing, the fines and jail terms, imposed by the courts, whether through criminal convictions after trial, or through negotiated guilty pleas, have been astounding.

The purpose of this article is to summarize these developments, provide a legal analysis of the issues involved and suggest certain guidelines for corporate executives to observe in order to minimize their corporate and personal risks of this increased vigilance and enforcement of the United States antitrust laws with respect to international operations.

This article focuses on "extraterritorial" enforcement of the U.S. antitrust laws. Extraterritorial enforcement of the U.S. antitrust laws generally refers to the application of these laws to conduct and activities which occur primarily beyond the geographic boundaries of the U.S., but which impact commerce within, or exportation from, the United States. Through extraterritorial enforcement of the U.S. antitrust laws, companies and individual executives and employees engaged in anticompetitive discussions or agreements in an office in Japan (or anywhere in the world) may be subject to enforcement of the U.S. antitrust laws and criminal penalties, even if these companies or individuals have never visited the U.S. or have never even sold their products in the U.S. Of course, before the conduct can become subject to the jurisdiction of the U.S. antitrust laws and the enforcement scrutiny of the DOJ, there is a requirement that the conduct was intended to produce, and in fact caused, some substantial harmful effect to competition in the United States.

During the administration of President Clinton, particularly in very recent years, the DOJ has substantially stepped up extraterritorial enforcement of the U.S. antitrust laws. The DOJ itself generates considerable publicity to the huge and increasing numbers and amounts of fines imposed by the DOJ and U.S. courts, particularly fines levied against international businesses and their executives. Moreover, several executives have recently been sentenced to substantial jail terms as result of their violations of the U.S. antitrust laws. Just as significant for international businesses, the DOJ has sought to expand the reach of its jurisdiction to attack conduct which may have been previously "ignored" by U.S. and local competition enforcement authorities.

This trend can impose significant risks for international businesses, particularly if these businesses are relying on "local" competition law and policy, which may be more lenient in scope or enforcement than current U.S. antitrust law and policy. The U.S. antitrust laws are often more developed through case law, and more vigorously enforced through civil and criminal action, than the unfair competition and antimonopoly laws of many other countries.

The U.S. federal antitrust laws, and their state counterparts, proscribe numerous forms of anticompetitive behavior, including, but not limited, to: allocation of production, markets or customers; bid rigging; boycotts and refusals to deal; actual or attempted monopolization; predatory pricing; price discrimination; price fixing; and tying. The U.S. antitrust laws govern both horizontal (relations between competitors) and vertical (relations between a supplier and its distributors/customers) conduct and agreements. Some of these activities, particularly price fixing and horizontal market allocation, are very susceptible to criminal enforcement by the DOJ if, in the view of the DOJ, these activities do, or will likely, adversely impact competition or commerce in the United States.

II. Increasing Fines
Most notably, the DOJ has sought to impose increasing fines against international companies, primarily international cartel members. These fines are increasing in size at a startling pace. In 1997, the Antitrust Division of the DOJ obtained over $200 million in criminal fines. In 1998, the Antitrust Division obtained over $265 million in criminal fines. As of July 1999, although the year is not much more than halfway over, the Antitrust Division has already obtained criminal convictions or guilty pleas involving fines in excess of $1 billion. Fines of this magnitude have never before been imposed as a result of U.S. antitrust violations. A large percentage of these fines have been imposed against international companies based on the DOJ's extraterritorial antitrust enforcement efforts. In many respects, it appears that the DOJ is focusing its antitrust enforcement with respect to activities or conduct occurring abroad and is aggressively conducting criminal investigations against non-U.S. companies (although domestic enforcement also remains a priority).

The U.S. antitrust laws, including the Sherman Act, the primary U.S. antitrust statute involved in extraterritorial enforcement, provide for a "maximum" penalty of $10 million for corporations and $350,000 for individuals, per violation . However, notwithstanding the statutory maximum penalties under the specific antitrust laws, under U.S. criminal laws, generally, U.S. courts may increase criminal fines up to an amount equal to either (i) twice the gain all conspirators derived from their unlawful conduct, or (ii) twice the loss suffered by all victims of the crime . Under the United States Sentencing Guidelines, U.S. courts can impose fines far in excess of the statutory maximum penalties under the antitrust laws . As a result, in recent years, the DOJ has obtained fines, and violators have pled guilty, and have agreed to pay fines, far in excess of the $10 million maximum statutory amount provided under the antitrust laws. In fact, it appears that the DOJ is imposing "record breaking" fines one week after another.

Significantly, in May 1999, the DOJ negotiated guilty pleas from two large vitamin manufacturers, F. Hoffman-La Roche Ltd. of Switzerland and BASF Aktiengesellschaft of Germany, based on allegations that the two companies, together with others, engaged in a worldwide conspiracy to fix prices and allocate worldwide markets for vitamins. The DOJ obtained fines from Hoffman-La Roche and BASF of $500 million and $225 million, respectively. On July 23, 1999, one of Hoffman-La Roche's marketing executives pleaded guilty to violating the antitrust laws and to obstruction of justice and was sentenced to serve a four?month prison sentence and pay a fine of $100,000. On August 19, 1999, a second Hoffman-La Roche executive pleaded guilty and was fined $150,000 and sentenced to serve a five-month prison term.

It is significant to note that these fines and the terms of imprisonment resulted from negotiated plea agreements. Presumably, each defendant feared that the exposure would have been significantly greater through a trial rather than negotiation. Plea agreements will also customarily require participants (the corporations and the individuals involved) to disclose any other criminal antitrust activities by the company, its executives or employees or by other conspirators, and to provide cooperation and information to assist the DOJ in its enforcement efforts against others.

The DOJ has aggressively publicized its recent price fixing case against Archer Daniels Midland Co. ('ADM"), and other companies and their executives. ADM was charged with conspiring to fix the worldwide price of the livestock feed additive, lysine. In 1996, ADM pleaded guilty to the charges, paying a then-record $100 million fine. Other indicted competitors pleaded guilty and negotiated significant fines. In July 1999, three ADM executives who had been convicted on charges that they had conspired to fix prices or allocate markets for lysine were sentenced and received harsh criminal penalties. Two of the executives were each individually fined $350,000. All three ADM executives received prison terms, each ranging from two to two-and-a-half years.

Several recent DOJ international cartel cases have involved Japanese companies or their U.S. subsidiaries. These include, but are not limited to, the following:

Company Year Product Fine
Nippon Gohsei 1999 sorbates $21 million
Tokai Carbon Co. 1999 graphiteelectrodes $6 million
Showa Denko Carbon, Inc. 1998 graphiteelectrodes $32.5 million
Fujisawa Pharmaceuticals Co., Ltd. 1998 sodiumgluconate $20 million
Ajinomoto 1996 lysine $10 million
Kyowa Hakko Kogyo, Co., Ltd. 1996 lysine $10 million


In the Nippon Gohsei case, announced in July 1999, and in other cases, various company executives were fined $350,000 each. Additionally, in the early 1990s, a number of Japanese paper manufacturers and importers pleaded guilty and paid fines totaling approximately $6.5 million in response to criminal price fixing charges involving the thermal fax paper industry. A number of civil antitrust cases were brought against these companies as well.

This trend of large fines and vigorous criminal antitrust enforcement is expected to continue into the future, at least through end of the Clinton administration. It has been reported that approximately thirty five criminal grand juries are currently investigating international price fixing allegations dealing with various commodity cartels. Based on recent history, it is very possible that additional criminal fines and jail time will be assessed in the near future, against U.S., Japanese and other international companies. Thus, by the time this article is published, or read, it would not be surprising if even higher fines and greater criminal penalties are imposed for antitrust violations.

III. Expanding Reach Of The U.S. Antitrust Laws
Ninety years ago, businesses engaged in conduct beyond the borders of the United States were virtually immune to civil or criminal attack under the United States antitrust laws. This is clearly no longer the situation.

Over the years, the DOJ has sought to expand its jurisdiction over international conduct impacting commerce in the U.S. In this regard, the DOJ has been supported by Congress, the courts, the DOJ's own internal guidelines, and international agreements and treaties. As a result, the DOJ has aggressively expanded its interpretation of, and enforcement against, behavior which the DOJ believes substantially impacts and harms U.S. commerce.

1. Statutory
In an effort ostensibly designed to clarify policy regarding the extraterritorial application of United States antitrust laws, Congress enacted the Foreign Trade Antitrust Improvements Act of 1982 (the "Act") . However, the Act did not substantially alter existing U.S. court precedent regarding extraterritorial enforcement of the federal antitrust laws.

The Act seems to contain certain denials of subject matter jurisdiction under the U.S. antitrust laws with respect to international conduct; but there are very broad exceptions. In essence, the Act provides that the U.S. antitrust laws do not apply to any foreign or domestic activities that affect foreign consumers, manufacturers or markets, unless there is a "direct, substantial and reasonably foreseeable effect" on U.S. commerce, including domestic U.S. markets and/or export opportunities. Practically speaking, the Act is a liberal statement, inviting aggressive extraterritorial enforcement of the U.S. antitrust laws, as long as U.S. commerce is substantially impacted.

2. Judicial
As suggested above, courts applying the U.S. antitrust laws to extraterritorial conduct have traditionally interpreted the U.S. antitrust statutes as requiring a substantial effect upon U.S. commerce before exercising jurisdiction. Still, in recent decades, U.S. courts have been quite willing to find that U.S. commerce has been substantially impacted by conduct or agreements which occur primarily outside the U.S.

The most recent United States Supreme Court opinion on the issue of extraterritoriality was the 1993 civil antitrust case, Hartford Fire Insurance Co. v. California. In Hartford Fire, nineteen states and numerous private parties filed antitrust suits against domestic insurers, domestic and foreign reinsurers and insurance brokers which had jointly agreed to a boycott to force primary insurance companies to change certain terms of their commercial general liability policies. It was undisputed that most of the meetings and other conduct in question occurred in London, England. The main issue before the U.S. Supreme Court was whether principles of international comity (deference to foreign laws and policy) required the U.S. courts to decline the exercise of jurisdiction over the foreign insurance companies. In a close 5-to-4 decision, the Supreme Court held that the conduct sufficiently affected U.S. commerce to permit the application of U.S. antitrust laws with respect to the extraterritorial conduct.

In arriving at its decision, the Supreme Court seemingly employed the three part analysis from the Alcoa case. First, there must be an actual or intended effect on U.S. commerce for the U.S. courts to exercise jurisdiction over the foreign companies. Second, there must be a sufficiently large harm resulting to commerce in the U.S. Third, U.S. courts must balance the interests of the U.S. with the interests of other nations.

The Supreme Court in Hartford Fire stated that the "Sherman Act applies to foreign conduct that was meant to produce, and did in fact produce, some substantial effect in the United States." The Court stated that, even though one of the reinsurers may have attended only a single meeting where the boycott was discussed, that company could still have violated the U.S. antitrust laws and, therefore, become subject to sanctions under the U.S. antitrust laws.

Notably, the Court held that principles of international comity may apply to bar the exercise of U.S. jurisdiction, but only when there is a need to avoid a clear and direct conflict between the U.S. antitrust laws and the controlling law of the foreign state. In Hartford Fire, certain of the insurers claimed that their conduct was entirely lawful under British law. However, the Court stated that this would not be relevant to the jurisdiction analysis, unless British law compelled the insurers to act contrary to the U.S. law. None of the insurers argued that they were so compelled.

Thus, the United Stated Supreme Court in Hartford Fire all but eliminated the third element of the Alcoa test, which previously required a balance of U.S. antitrust law and policy against principles of comity. In so ruling, the Court effectively expanded the jurisdiction of the U.S. antitrust laws, removing barriers for increased extraterritorial enforcement by the DOJ.

However, even with this liberal standard, in a recently concluded criminal trial, a U.S. District Court declined to find that Nippon Paper Industries Co., Ltd., and its predecessor company, Jujo Paper Company, Ltd. (collectively, "Nippon Paper"), violated the U.S. antitrust laws. In this case, the U.S. government alleged that, beginning in 1990, Nippon Paper conspired with other manufacturers in Japan to fix the price of thermal fax paper for export into the U.S. At the conclusion of a jury trial on the criminal charges, the District Court directed a verdict of acquittal and held that the U.S. government failed to meet its burden of proving that the conspiracy had a substantial effect on U.S. commerce.

Citing the Hartford Fire case and other precedents, the District Court noted that the government was required to prove that the conduct had an "intended," as well as "substantial" effect on U.S. commerce. The U.S. government alleged that the conspiracy, to the extent it involved Nippon Paper, begin in 1990. However, the court found that companies in the United States, by 1990, had already achieved the capacity to supply the entire demand for thermal fax paper in the United States. Therefore, the court did not believe that the alleged conspiracy could possibly have had a "substantial effect" on U.S. commerce. The court emphasized that "a substantial effect on United States commerce cannot simply be assumed to continue because it once existed."

As highlighted by the Nippon Paper case, not all foreign conduct having some impact on U.S. commerce will justify the exercise of jurisdiction under the U.S. antitrust laws. The anticompetitive impact in the U.S. must be substantial and injurious. However, the standard remains relatively liberal and supports the DOJ in its expansion of international antitrust enforcement. It is also important to note that the Nippon Paper case, is only a district court opinion and has limited precedential weight and should not be relied on by those contemplating involvement in international conduct or agreements which are intended to, or likely will, affect U.S. commerce.

3. DOJ/FTC Guidelines
In 1995, the DOJ and the FTC, the other primary U.S. antitrust enforcement agency, jointly issued updated Antitrust Enforcement Guidelines for International Operations. The Guidelines state that they are "intended to provide antitrust guidance to businesses engaged in international operations on questions that relate specifically to the Agencies' international enforcement policy." In effect, the Guidelines highlight the aggressive expansion of extraterritorial antitrust enforcement by the DOJ and FTC.

The Guidelines include descriptions of relevant antitrust laws enforced by the DOJ and FTC; the issues and policies that relate to the Agencies' decision whether to exercise jurisdiction over conduct and entities beyond the geographic borders of the U.S.; issues of international comity; and related matters. The Guidelines have been interpreted as a warning to foreign companies that the DOJ and FTC intend to actively attack anticompetitive conduct occurring abroad that substantially affects U.S. commerce. It has been said that the Guidelines focus on legal issues such as jurisdiction, rather than practical use in business planning. Nevertheless, the Guidelines may be helpful to any business interested in learning more about current U.S. antitrust enforcement policy.

The Guidelines set forth a number of hypothetical cases designed to illustrate the current broad enforcement policies of the DOJ and FTC. It is possible to summarize only a few of these hypotheticals in this article.

One of the hypothetical cases suggests that the DOJ will assert jurisdiction and challenge anticompetitive conduct of, and assert jurisdiction over, cartel members that utilize intermediaries (e.g. trading companies or agents) located outside of the U.S. to sell into the U.S., even if the cartel members themselves do not directly sell into the U.S., or have U.S. subsidiaries or manufacturing facilities. This hypothetical implies that the DOJ may be willing stretch existing concepts of jurisdiction when necessary to thwart anticompetitive behavior impacting commercial activity or competition in the U.S.

While not directly related to criminal enforcement, the Guidelines also reflect the FTC's policy to scrutinize mergers involving international companies where such mergers may substantially impact commerce in the U.S. In fact, one of the hypothetical cases in the Guidelines suggests that the FTC will assert jurisdiction over a proposed merger involving two foreign companies that each export into and maintain sales offices in the U.S., even if neither has any manufacturing facilities in the U.S.

4. International Agreements/Treaties
The U.S. has recently entered into a number of bi-lateral international antitrust enforcement/cooperation agreements and treaties with foreign nations. For example, on May 3, 1999, President Clinton and Prime Minister Obuchi announced that the U.S. and Japan reached "accord" on an antitrust cooperation agreement. The stated purpose of the proposed agreement is to "allow the antitrust agencies in the two countries to combat anticompetitive activities more effectively." Although the effects of this accord and cooperation activities remain to be determined and may be largely affected by the course of evolving antitrust enforcement by Japanese authorities under Japan's Anti-Monopoly Law, significant elements of the accord include:

Notification of Enforcement Activities. Each country's antitrust agencies will notify their counterparts in the other country concerning antitrust enforcement activities that may affect the other's important interests.
Enforcement Cooperation and Coordination, and Positive Comity. The antitrust agencies will consider cooperating, and, when appropriate, will consider coordinating their activities, consistent with the other country's enforcement interests.
Positive Comity. Each antitrust agency will give careful consideration to a request by the counterpart agency to take antitrust enforcement action against illegal behavior occurring within its country that injures the other country's interests.
Conflict Avoidance. The parties will consider one another's interests in carrying out enforcement activities. The proposed agreement includes a non-exhaustive list of factors to be considered in this regard.
Consultations and Exchange of Information. The parties will consult with each other on matters which arise under the agreement. The parties agree to exchange antitrust-related information, within applicable confidentiality restraints.
Existing Laws. The agreement will be implemented in accordance with existing laws in each country.
It was announced that the agreement will be signed in the near future.

In theory, the proposed cooperation agreement could potentially lessen extraterritorial enforcement of the U.S. antitrust laws, by allowing the Japanese government to redress anticompetitive behavior initiated within Japan. As a practical matter, however, given the recent trend of extraterritorial enforcement of the U.S. antitrust laws, it appears unlikely that the U.S. will subordinate its antitrust enforcement efforts to principles of comity.

The U.S. has entered into similar, and even more detailed, cooperation agreements with Canada, Australia and with countries within the EC.

IV. Conclusion/Suggestions
In the present aggressive enforcement atmosphere, no business, wherever located, should engage in any type of conduct which conceivably could violate the criminal antitrust laws of the United States without a careful and full understanding of all of the risks and benefits of that conduct, and, in so doing, must obtain competent legal advice from attorneys knowledgeable about the United States antitrust laws. No longer can businesses assume, as they may have in the past, that, their agreements with competitors, with respect to issues such as pricing, market or customer allocations, or production quotas, will be immune from scrutiny or criminal investigation and enforcement by the United States antitrust officials merely because their meetings or agreements occur entirely outside the United States.

As a general rule, businesses, wherever located, should avoid participating in discussions or meetings, or entering into agreements with competitors, where the subject matter involves pricing, market or customer allocations or reduction in manufacturing capacity. If U.S. commerce or competition is, or may be, impacted by such discussions or agreements, whether directly or indirectly, such activities may expose all participants, including individuals, to substantial risks under the U.S. antitrust laws. No one should assume that such conduct is immune to attack by U.S. antitrust officials simply because it occurs outside of the U.S. or does not directly involve sales in the U.S.

Any business that has questions regarding the extraterritorial enforcement of the U.S. antitrust laws should certainly review the 1995 Antitrust Enforcement Guidelines for International Operations issued by the DOJ and FTC, and the hypotheticals contained in the Guidelines. While the Guidelines may not be helpful with respect to highly specific questions of strategic business planning, the Guidelines are still a good starting point for a company to obtain a sense of U.S. antitrust enforcement policy.

Moreover, the DOJ and FTC each maintain a web site from which any interested business or individual can obtain recent press releases and policy statements, including various Guidelines, to obtain a current understanding of announced enforcement activities and policies. The address of the DOJ's web site is "WWW.USDOJ.GOV". The address of the FTC's website is "WWW.FTC.GOV".

In an appropriate case, a foreign or domestic business can participate in the DOJ's "Business Review Procedure," which allows parties to seek the Antitrust Division's enforcement intentions with respect to specific prospective conduct. This, of course, is a process that should only be utilized with the advice and assistance of legal counsel. The DOJ's responses are not binding, but can provide helpful insight and guidance.

Most large U.S.-based corporations have already adopted, and encourage their executives and employees to strictly observe, an Antitrust Compliance Policy. The extent to which a company has adopted, implemented and encouraged observance of such a Policy will be considered a significant factor by enforcement agencies in their decisions concerning prosecution, and by the courts in determining an appropriate sentence, under the Sentencing Guidelines. Excellent examples of Antitrust Compliance Policies of several major U.S.-based international corporations are readily available from several publishers .

In certain cases, upon advice, and with assistance, of legal counsel, a company or individual may seek to participate in the Antitrust Division's "Corporate Leniency Program." Under this Program, which also has an "Individual Leniency Program" counterpart, participants may qualify for protection from, or a reduction in, criminal prosecution, if they voluntarily report their own involvement in anticompetitive conduct. Participants must satisfy certain other criteria. Generally speaking, participants are required to provide information regarding the their own "crimes" as well as the anticompetitive conduct of others. According to the DOJ, this Program has led to significant prosecutions and fines by the DOJ, including the recent $725 million fines in the Hoffman-La Roche and BASF cases. The DOJ announced that a French pharmaceutical company (Rhone-Poulenc, SA) cooperated in that investigation pursuant to the DOJ's Corporate Leniency Program and thereby escaped criminal penalties. Similarly, in the graphite electrodes investigation, leniency was sought and obtained by a corporation (Carbide/Graphite Group, Inc.) which enabled that company and its executives to avoid criminal fines and imprisonment. Current versions of the Corporate and Individual Leniency Programs are available on the DOJ's website.

Enforcement of the U.S. antitrust laws, including domestic and extraterritorial enforcement, is tied to the political process. Antitrust enforcement, at least criminal enforcement, is certainly on the rise. However, the Clinton presidency is almost at an end, and it is yet to be seen how future administrations and antitrust officials will enforce these same laws.


For more information, please contact Jerrold Fink or Steven Katz.



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