ABSTRACT
Representatives of the European Union have raised the prospect of a convergence of American antitrust law and European competition law. One must keep in mind, though, that capital markets, corporate governance and competition policy have developed in a different manner in the two economic areas. In the US, modern antitrust legislation began in 1890 with the Sherman Act. From the 1980s on, in accordance with the Chicago school, efficiency considerations gained weight.1 In Europe, in contrast, competition policy developed in a different manner.
