16 - Leniency Programmes in Asia

Summary

The concluding chapter argues that the Asian leniency programmes only converge on the core elements of a leniency programme. The core elements are the building blocks of a leniency programme. However, the composition of these blocks is often different. Some of the differences are subtle. Other differences make the respective leniency programme distinct from the others. Some of the distinctive elements are not necessarily part of the building blocks any more and thus give a unique character to the respective leniency programme. This chapter further claims that these differences can be explained by either the political economy of a country, experimentation due to prior negative enforcement results and a desire to achieve better enforcement results, or foreign influence. Since the result of experimentation cannot always be predicted, the authors estimate that further amendments will be made to the Asian leniency programmes.