Frank Montag


This Essay first describes the shortfalls of the current enforcement regime under Regulation 17 and the practical problems that undertakings experience in enforcement proceedings. It then discusses the suggestions for reform of Regulation 17. Finally, this Essay illustrates that although amendments and changes to the current procedural rules could solve some of the problems undertakings are facing in competition proceedings today, in order to address these problems effectively, changes to the underlying institutional system will be necessary.