Enforcement of national judgments, acts or decisions of national antitrust authorities abroad

It is necessary to distinguish those situations where antitrust authorities have independent authority to impose fines or issue cease and desist orders, which then take effect directly and are not required to be issued through the authority of a court (e.g. EEC, Germany), from those where antitrust agencies proceed through the medium of the courts in acting against the antitrust violators (e.g., USA, U.K.). Different again are those systems which rely partly upon private actions brought by individuals for the enforcement of antitrust law provisions (e.g. USA, Switzerland). In the first situation described there may well be appeal procedures before the courts, as indeed there are in the two jurisdictions cited as examples.