US and Turkish Antitrust and Competition Law: A Practical Comparison
Both the United States and Türkiye operate competition regimes that target the same broad categories of harm: cartels, anticompetitive mergers, and abuse of market dominance. The substantive overlap is real, and from the outside the two regimes look like close cousins. The closer you get, however, the less they resemble each other. The differences run deep, and they shape outcomes far more than the headline similarities suggest.
This article maps the most important of those differences, with the Turkish lawyer or executive in mind whose company has touched, or is about to touch, the US market. American counsel looking the other way will find what they need here as well. Each side tends to underestimate how unfamiliar the other system feels until they are operating inside it.