This chapter introduces one of the more recent leniency programmes in Asia. Due to the dual enforcement structure, the Philippines has developed two different leniency programmes, one administered by the Philippine Competition Commission and one by the Office for Competition of the Department of Justice (DOJ-OFC). Whereas the latter is only applicable in criminal proceedings, the former applies to administrative, criminal and civil proceedings. The chapter argues that both leniency programmes are generous. However, discretionary powers of the enforcement agencies and the possibility of carving employees out of the leniency application diminish the attractiveness of leniency programmes. Uncertainty about the outcome of a leniency application has, in general, not been well accepted by cartel participants. It can therefore be predicted that, no matter how generous the leniency programmes are, there will be no race to the enforcement agencies’ doors.

Polish competition law is characterized by the strong predominance of public enforcement. The crucial component of the Polish system of sanctions has always been administrative corporate fines regulated in much the same way as under EU Law. So far, however, the Polish competition law does not recognize the concept of the single economic unit. This means that the amount of fine is always calculated on the basis of the whole or a part of a direct infringer's turnover. Similarly the fines imposed on associations of undertakings are calculated exclusively on the basis of an association’s turnover. Such a concept of undertaking contributes to the intensification of one of the problems related to enforcement of Polish competition law: the low level of fines imposed by the Competition Authority (CA). The 2014 ACCP amendment introduced into the Polish system individual administrative fines of up to PLN 2 million (c. EUR 450,000) for intentional infringements of the prohibition of anticompetitive agreements, and remedies which may be imposed with or without a fine. These amendments may have significant impact on the effectiveness of the Polish competition law system, in particular by strengthening the deterrent effect of the decisions of the CA.

Turkish competition law provides a dual enforcement structure that consists of public and private enforcement. Although the legislator has attached considerable weight to private enforcement by enabling the claimants to sue for threefold damages, it is fair to say that the Act on the Protection of Competition mainly relies on public enforcement. The Act empowers the Turkish Competition Authority to enforce the law and sets out various sanctions, including structural remedies, which equip the Authority with broad powers in combating anticompetitive behavior. The prime sanction is administrative monetary fines which are based on the turnover of the infringing undertaking and can be set at a maximum level of 10 percent of the turnover of the infringing undertaking. The Act also authorizes the Authority to implement monetary fines to managers and employees in cases where they have considerable influence in the formation of infringement. Anticompetitive behavior is a misdemeanor; however, in bid-rigging, it can also give rise to a crime and trigger harsh criminal sanctions. It is generally accepted that the Act provides severe penalties for infringements; however, in practice, the sanctions have been applied somewhat inconsistently, basically due to the fact that enforcement policy lacks coherent policy goals.

In 1921, Finland was the first Nordic country to introduce the day fine system into its system of criminal sanctions. The main reason for adopting the new system was an attempt to introduce a system where fines would have an equal impact on people with varying means.An important objective of the total reform of Finnish criminal law (1980–2003) was to reduce of custodial sentences and, therefore, the increased use of financial sanctions had a preference. In a comparative analysis day fines are imposed to very great extent in Finland.There has been a general satisfaction with the fining system in Finland.The efficiency of the day fine system has been furthered by the detailed provisions on the assessment of the person’s income and the effective enforcement of fines. As for the future of the fining system, there is an urgent need of coordinating various punitive pecuniary sanctions (whether they are criminal in nature or administrative and whether they are day fines or fixed fines).