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Enforcement of Administrative Fines

In Turkey ‘effect theory’ jurisdiction is applicable, regardless of where the infringement has taken place and/or what the nationalities of the cartel companies are and/or whether the members have a subsidiary in Turkey, if the cartel activity has produced effects on Turkish markets, the Board adjudicates over non-Turkish cartels or cartel member companies. It should be noted, however, that it is difficult in practice for the Board to enforce monetary or other sanctions against companies located outside of Turkey without any presence in Turkey, mostly due to enforcement difficulties of official service to foreign legal entities.

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