At high energies, the relevant degrees of freedom are Wilson lines - infinite gauge links ordered along straight lines collinear to the velocities of colliding particles. The effective action for these Wilson lines is determined by the scattering of QCD shock waves. I develop the symmetric expansion of the effective action in powers of strength of one of the shock waves and calculate the leading term of the series. The corresponding first-order effective action, symmetric with respect to projectile and target, includes both up and down fan diagrams and pomeron loops.

15 pages, 10 eps figures