National competition regulators in the EU regularly investigate very narrow and small markets, not least in the cartel field. The UK CMA provided an example recently when it fined estate agents for implementing a price-fixing arrangement in one small town (Burnham-on-Sea).

Under the arrangement, the companies colluded to set minimum commission rates for residential property sales at 1.5 percent, with a view to denying local homeowners selling their property the chance of securing a better deal. One participant was not fined as it was the first company to confess its participation in the cartel.

The case shows that every company active in the UK needs to consider its competition law compliance arrangements and make sure it has an appropriate policy and training in place. Well-designed arrangements can identify potential wrongdoing and therefore allow the company to self-report wrongdoing and potentially protect itself from fines.