Answer ... Companies faced with a cartel investigation, which often starts with a dawn raid, should immediately commission an internal investigation of the allegations which can be derived from the search warrant presented during the dawn raid. In any case, and especially if the cartel investigation was likely triggered by a leniency applicant (ie, another member of the cartel), companies faced with a cartel investigation should clarify the facts internally as quickly as possible through searches of email accounts and interviews with potentially involved employees. Time is of the essence with respect to a potential leniency application, as the Federal Cartel Office (FCO) will base the amount of the fine reduction of subsequent applicants on the sequence of applications, among other things. If an internal investigation confirms the allegations, the company must decide whether to apply for leniency by placing a marker with the Federal Cartel Office. Once a company has applied for leniency, it should ensure that it complies with the duty to cooperate fully and on a continuous basis with the FCO.