Le programme de clémence américain : un modèle placé sous le sceau du pragmatisme
| Auteur | Legal News |
Le concept de politique de clémence est né aux Etats-Unis en 1978 avant d'être repris à travers le monde, le programme de clémence communautaire s'étant, à l'instar du programme français, largement inspiré du modèle américain. Ces deux programmes sont toutefois d'une nature différente de celle du droit antitrust américain, qui prévilégie l'action privée sur l'action publique, en faisant le choix des "punitive damages". Dans le présent article, Anne Tercinet se propose d'exposer le...
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