Fines levied against cartel perpetrators worldwide reached a high water mark in 2015 and 2016, when a handful of outsized penalties skewed the numbers upwards, and the totals have been coming down since. But experts say there's been no major policy shift or change in enforcers' focus to account for the drop off. Instead, a confluence of factors has led to the trend. Phelan said, "Is there a lull now? I think it would be hard to deny. The question is, why? And there's not one factor, there's sort of a collection of factors."