Antitrust Audit for Businesses in Kazakhstan

We review contracts, pricing policies, discounts, rebates, supply terms, dealer and distribution agreements, and sales practices for potential competition law risks. Following the audit, your company receives a structured risk map and practical recommendations on how to address the identified issues.

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When Should a Company Consider an Antitrust Audit?

  • Pricing or Commercial Terms Are Being Changed
    If the company is revising prices, tariffs, mark-ups, discounts or supply terms, it is important to assess whether the new rules could create risks of discriminatory treatment or raise competition law concerns.
  • The Company Holds a Significant Market Position
    The stronger the company’s market position, the more carefully it should assess refusals to supply, changes in commercial terms, exclusivity arrangements, individual pricing and access to products or services.
  • Complex Discounts & Rebate Structures Are Used
    Complex incentive structures may appear commercially reasonable within the company but can raise questions where comparable customers receive different terms without clear and objectively documented criteria.
  • Customers, Suppliers or Competitors Have Filed Complaints
    Even where a complaint has not resulted in an investigation, it may indicate that certain elements of the company’s commercial model are perceived by market participants as potentially problematic.
  • The Company Operates a Dealer or Distribution Network
    Agreements with dealers, distributors, agents, franchisees and other partners may include territorial, pricing, customer, product-range or sales-channel restrictions. Such provisions may require specific competition law review.
  • A Transaction, Reorganisation or Business Expansion Is Planned
    Before acquiring assets, combining businesses, entering a new market or significantly expanding sales, it can be useful to assess competition law risks in advance.
Does Your Company Need an Antitrust Audit?
What Would You Like to Review First?
Which Commercial Practices Are Used by Your Company?
Does Your Company Work with Dealers, Distributors or Other Partners?
Does Your Company Hold a Significant Market Position?
Has Your Company Faced Any Complaints, Regulatory Requests or Disputes?
Does Your Company Have Approved Internal Policies and Procedures?
Which Documents Can You Provide for an Initial Review?
How Urgently Do You Need the Audit?
Leave your contact details and a MonoEX Consulting specialist will review your answers, identify the areas that should be assessed first and recommend the most appropriate audit format for your company.
Get a Preliminary Antitrust Audit Assessment
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Answer a few questions and we will make a preliminary assessment of which areas should be reviewed — contracts, pricing, discounts, distribution arrangements, procurement, communications or sales policies.

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An Antitrust Audit Identifies Risks Before They Become Regulatory Issues
The review goes beyond formal legal documentation. We analyse how the business actually operates — how prices are set, discounts are granted, dealers and distributors are managed, customer requests are handled, procurement processes are conducted and counterparties are treated.
An audit is particularly useful when a business is growing, changing its pricing policy, introducing new sales terms or has already faced regulatory requests, complaints or increased attention from the competition authority.
The main objective is to identify weaknesses early and address them before they become the subject of a regulatory claim, complaint or investigation.

Why Businesses Choose MonoEX for Antitrust Audits

  • Review of Actual Business Practices
    We assess not only formal policies and contracts but also how the company actually sells, purchases, grants discounts and interacts with customers, suppliers, dealers and other market participants.
  • Focus on Competition Law Risks
    The audit focuses on risks that may arise in interactions with the APDC, counterparties, competitors and procurement participants.
  • Clear Conclusions for Business Teams
    Audit findings are presented in a format that can be understood and applied by legal teams, management, commercial departments, sales and procurement functions.
  • Practical Recommendations
    We do not simply list potential issues. For each material risk, we recommend practical actions — for example, revising a contract, clarifying discount criteria, introducing an approval procedure or training employees.
Common Issues Identified During an Antitrust Audit
Discounts are granted without clear and consistent criteria
Comparable customers receive different terms without documented justification
Dealer agreements contain problematic territorial or customer restrictions
Employees use potentially sensitive wording in business communications
Supply terms are changed without a defined internal approval process
Refusals to supply are not properly documented
There is no consistent pricing policy
Promotions are launched without competition law review
Standard contracts are reused for years without being updated
Employees do not know how to respond to regulatory requests or complaints
The company has no structured competition risk map or clearly assigned responsibility for monitoring risks

Many competition law risks do not arise from deliberate misconduct. They arise because the company lacks a consistent framework for making and documenting commercial decisions. An audit helps identify these weaknesses before they attract the attention of the regulator or a market participant.

Competition Law Risks an Antitrust Audit Can Help Identify

  • APDC regulatory risk
  • Complaints from competitors, customers or suppliers
  • Discriminatory commercial terms
  • Unjustified refusals to supply
  • Resale price maintenance risks
  • Market or customer allocation risks
  • Abuse of dominance risks
  • Anti-competitive agreements and concerted practices
  • Pricing policy risks
  • Unjustified discounts, rebates and promotional practices
  • Risks in dealer and distribution agreements
  • Sensitive or potentially problematic communications with competitors or counterparties

  • 10+ Years of Team Experience

  • 200+ Clients Across Kazakhstan

  • Complex Cases Handled with Confidence

  • Measurable Business Outcomes

Antitrust Compliance

If the audit identifies systemic risks, we can develop an Internal or External Antitrust Compliance Act and implement practical controls for managing competition law risks.

  • Competition Authority Representation

    If the audit follows an APDC request, complaint or notice, the company may need a structured legal position and support in communications with the competition authority.
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  • Ongoing Antitrust Advisory

    If the company regularly changes prices, discounts, contracts or other commercial terms, ongoing advisory support allows these decisions to be reviewed before implementation.
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Which Businesses Benefit Most from an Antitrust Audit?
  • Regulated & Competition-Sensitive Industries
    Energy, transport, telecommunications, petroleum products, pharmaceuticals, medical devices, FMCG, retail, utilities, infrastructure and other competition-sensitive markets.
  • Manufacturers
    Particularly where the company sets prices, manages supply, works with dealers, allocates products between customers or offers individual commercial terms.
  • Distributors & Wholesalers
    Where the business serves multiple customer categories, uses different discount structures, applies regional terms or works with exclusive partners and suppliers.
  • Retailers & Retail Chains
    Where the business manages complex supplier terms, marketing rebates, promotions, special arrangements, assortment requirements or disputes relating to access to retail channels.
  • Companies with Dealer Networks
    Where contracts contain territorial restrictions, sales-channel conditions, pricing provisions, customer restrictions or rules governing relationships between dealers.
  • Corporate Groups & Holdings
    Where commercial decisions are made across different legal entities, branches or business units without a consistent competition law control framework.
  • Companies with Significant Market Share
    Where pricing decisions, refusals to supply, changes in commercial terms or the selection of business partners may be assessed in the context of a dominant market position.
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Laura Ibraimova
Director, MonoEX Consulting
Professional Background
Education
MBA, Master of Business Administration, UBIS, Geneva.

Professional Experience
  • 10+ years of experience with Kazakhstan's competition authority at regional and national levels
  • Extensive litigation and regulatory methodology experience
  • Participation in the development of regulations relating to competition and antitrust matters
Leadership Experience
Managing Director for Government Relations and Analytics at the Association of Mining Companies of Kazakhstan.
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What We Review During an Antitrust Audit
We do not analyse documents in isolation. We review the broader commercial logic of the business — from contractual terms and pricing decisions to the way employees apply discounts and communicate with counterparties.
  • Customer & Supplier Agreements
    We review supply and payment terms, refusals to deal, penalties, exclusivity provisions, allocation of responsibilities and differences in commercial terms offered to counterparties.
  • Dealer & Distribution Agreements
    We assess territorial and customer restrictions, resale pricing provisions, product ranges, sales channels, marketing arrangements and exclusive rights.
  • Pricing Policies
    We review how prices, tariffs, mark-ups, individual offers and special commercial terms are determined and approved internally.
  • Discounts, Rebates & Promotions
    We assess whether discount criteria are clear, objective and consistently applied and whether rebate or promotional mechanisms could be perceived as discriminatory or restrictive of competition.
  • Sales & Distribution Policies
    We analyse how products are allocated, how sales channels are managed, how supply terms are established and how the company deals with different customer categories.
  • Procurement & Tenders
    We review procurement practices, communications with other market participants, tender documentation and potential risks of coordinated conduct.
  • Business Correspondence & Internal Communications
    We identify potentially sensitive wording in business correspondence, commercial proposals and communications with dealers, suppliers, customers and competitors.
  • Internal Policies & Approval Procedures
    We assess whether the company has clear internal rules for approving prices, discounts, contracts, promotions, regulatory responses and interactions with the competition authority.
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Our Expertise
  • Experience
    Hands-on experience with antitrust investigations involving major market participants.
  • Regulatory Experience
    Our team includes professionals with extensive practical experience within Kazakhstan’s competition authority at regional and national levels, including senior positions.
  • Litigation Expertise
    Extensive litigation experience and representation of business interests before courts at various levels.
Competition & Antitrust Law
Competition Authority Representation
Antitrust Compliance
Merger Control
Antitrust Audit
Ongoing Antitrust Advisory
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Why Businesses Choose MonoEX Consulting

  • Specialist Competition Law Focus
    We focus on competition law, antitrust audits, compliance, merger control and ongoing business advisory.
  • Practical Business Approach
    We analyse not only legal documentation but also actual business processes — pricing, discounts, contracts, sales, procurement, dealer relationships and interactions with counterparties.
  • Support Beyond the Audit
    Our work does not end with the audit report. Where required, we help revise contracts and policies, implement compliance measures, train employees or establish ongoing competition law controls.
  • Nationwide Coverage
    MonoEX Consulting is based in Astana and advises businesses throughout Kazakhstan.
  • Practical Documents for Business
    We prepare risk maps, recommendations and revised documents that can be used in the company’s day-to-day operations rather than formal legal texts intended simply for filing purposes.
  • Responsive Client Support
    Our team remains accessible to clients throughout the audit and implementation process.
Discuss Your Competition Law Risks with Our Team
Tell us about your business, contracts and commercial practices. We will make a preliminary assessment of which areas should be reviewed and recommend the most appropriate audit format.

How We Conduct an Antitrust Audit

Define the Scope of the Review
We identify what needs to be assessed — contracts, pricing, discounts, dealer networks, procurement, correspondence, sales policies or a specific disputed situation.
Collect Documents & Information
We prepare a list of the required materials, including contracts, price lists, discount policies, commercial proposals, internal procedures, correspondence and sales-channel information.
Analyse the Commercial Model
We assess how the company works with customers, suppliers, dealers and partners, how pricing decisions are made and how commercial terms are established and documented.
Identify & Classify Risks
We classify identified risks by level — critical, significant, moderate or technical — and separately highlight areas that may attract the attention of the APDC.
Prepare a Risk Map & Recommendations
We describe each material risk, explain why it arises and recommend specific actions — what should be changed in contracts, policies, processes or communications.
Discuss Implementation
We present the findings to the client’s team and recommend the next steps — document revisions, antitrust compliance, employee training or ongoing competition law advisory.
Client Testimonials
Olga Smirnova
Competition Law Advice
The MonoEX Consulting team demonstrated a high level of professionalism and in-depth knowledge of competition law. Their support helped us address the risks and avoid potentially significant penalties.
Ivan Petrov
Expert Antitrust Advice
We were very satisfied with our cooperation with MonoEX Consulting. The team helped us navigate complex competition law issues and significantly reduce our regulatory risks.
Marina Vasilyeva
Preventing Antitrust Violations
With the support of MonoEX Consulting, we improved our business processes and reduced the risk of competition law violations. We highly recommend their team.
What Your Business Receives Following an Antitrust Audit
Our findings are designed to be useful not only to lawyers but also to management, commercial teams, sales, procurement and employees whose day-to-day decisions may create competition law risks.
  • A clear competition law risk map
  • A list of problematic contractual provisions
  • Assessment of pricing and sales policies
  • Findings relating to discounts, rebates, promotions and supply terms
  • Recommendations on dealer and distribution agreements
  • A list of required changes to documents and business processes
  • A prioritised action plan
  • Recommendations on internal controls and approval procedures
  • A foundation for implementing antitrust compliance
  • Better preparedness for communications with the APDC

Frequently Asked Questions About Antitrust Audits

Ideally, before introducing a new pricing policy, dealer agreement, rebate programme, major transaction or significant change to commercial practices. An audit can also be useful after the first complaints, disputes or regulatory concerns arise.