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2025 increases to HSR notification thresholds, filing fees, interlocking directorate thresholds, and HSR penalties

The Federal Trade Commission (FTC) has announced increases to the notification thresholds and premerger filing fees under the Hart-Scott-Rodino (HSR) Antitrust Improvements Act, which requires premerger notification of...more

How will the Trump administration impact M&A?

M&A practitioners anticipate a ‘Trump bump’ - The scale of Donald Trump’s victory in the presidential election – and the fact the Republicans now have full control of Congress – has been greeted with optimism by U.S....more

FTC and DOJ Finalize New HSR Rules (Updated November 12, 2024)

Democratic Commissioners Swung for the Fences, but FTC Settles for Unanimous Revisions, Still Increasing Burden on Filers - On October 10, 2024, all five Federal Trade Commission (“FTC”) Commissioners, with concurrence...more

U.S. DOJ seeks rare $3.5 million “gun jumping” penalty against Legends Hospitality for pre-closing conduct in connection with its...

On August 5, 2024, the United States Department of Justice (“DOJ”) filed a rare[1] gun jumping[2] civil lawsuit and proposed settlement in the United States District Court for the Southern District of New York against Legends...more

Laying a New Foundation – New FTC and DOJ Merger Guidelines Seek to Advance Biden Administration’s Aggressive Enforcement Vision

In the nearly three years since President Biden took office, it has become clear that his Administration has sought to develop an “inflection point” for antitrust enforcement. Speeches by new leadership at both the U.S....more

Field of Dreams: FTC and DOJ Seek to Build a New Playing Field for Challenging Mergers

Proposed FTC and DOJ Merger Guidelines Formalize Biden Administration’s Aggressive Vision for Merger Enforcement – Top Ten Takeaways - When losing, some players seek to change the rules. Others seek to change the playing...more

Proposed Overhaul of HSR Form Will Dramatically Increase Burden on Filers

Earlier this week, the Federal Trade Commission and the Antitrust Division of the U.S. Department of Justice (the “Antitrust Agencies”) announced proposed changes to the premerger notification process that mark the most...more

UPDATE: FTC’s Updated Filing Fees, Increased HSR Thresholds and Increased Interlocking Directorate Thresholds for 2023

The new Hart-Scott-Rodino Antitrust Improvements Act of 1976, as amended (the “HSR Act”) thresholds will go into effect on February 27, 2023 and will apply to all transactions closing on or after that date. As previewed in...more

Significant US HSR Filing Fee Changes Under The Merger Filing Fee Modernization Act

On December 29, 2022, President Biden signed into law The Consolidated Appropriations Act of 2023 also known as The Omnibus Funding Bill (the “Bill”). The Bill includes the Merger Filing Fee Modernization Act which provides...more

FTC Increases HSR Thresholds in 2022

On January 21, 2022, the U.S. Federal Trade Commission (FTC) announced the annual changes to the thresholds for the Hart-Scott-Rodino Antitrust Improvements Act of 1976, as amended (the “HSR Act”). The official publication is...more

Back to the Future—FTC Reinstates and Broadens Prior Approval Policy for Anticompetitive Mergers

On Monday, October 25, 2021, the Federal Trade Commission (FTC) voted along party lines to approve (3-2 with Commissioner Phillips and Commissioner Wilson dissenting) a new Prior Approval Policy Statement (Prior Approval...more

Proposed HSR Rules Affect Investment Firms/Master Limited Partnerships and Minority Acquisitions

The U.S. Federal Trade Commission (FTC) and U.S. Department of Justice Antitrust Division (“DOJ” and collectively, the “Agencies”) recently proposed changes to two aspects of the Hart-Scott-Rodino Act (“HSR Act”). The...more

DOJ/FTC Release Long-Awaited Vertical Merger Guidelines

The U.S. Department of Justice (DOJ) and the Federal Trade Commission (FTC) (collectively, “Agencies”) released the final version of the Vertical Merger Guidelines (“Vertical Guidelines”) on June 30, 2020. The new Vertical...more

Update — Antitrust and COVID-19

- US Agencies Encourage COVID-19-Related Collaboration - Practical Tips for Information Sharing & Document Creation - Possible Delays to US Merger Approvals The ongoing COVID-19 outbreak has, at least temporarily,...more

FTC Increases HSR Thresholds Effective February 27, 2020

On January 28, 2020, the U.S. Federal Trade Commission (FTC) announced the annual changes to the thresholds for the Hart-Scott-Rodino Antitrust Improvements Act of 1976, as amended (the “HSR Act”). The new size of transaction...more

Five Key Aspects of the Long-Awaited Revised Draft US Vertical Merger Guidelines

On Friday, the Federal Trade Commission (“FTC”) and the Antitrust Division of the U.S. Department of Justice (“DOJ”) released joint draft Vertical Merger Guidelines (“Guidelines”) for public comment. This much anticipated...more

Key Antitrust Enforcement Trends — 2019 Antitrust Annual Report

Welcome to the 2019 Shearman & Sterling Antitrust Annual Report. Our seventh edition focuses on the contrasting use by regulators of antitrust laws with respect to the FANGs, and how antitrust is being enforced in the U.S....more

Companies With Effective Antitrust Compliance Programs Could Get Relief From Criminal Prosecution Under New DOJ Policy

The Antitrust Division of the U.S. Department of Justice (Division) finally will consider the existence of effective antitrust compliance programs at the charging stage of criminal antitrust investigations, opening up the...more

FTC Increases HSR Thresholds Effective April 3, 2019

The U.S. Federal Trade Commission (FTC) has revised, and once again raised, the thresholds for the Hart-Scott-Rodino Antitrust Improvements Act of 1976, as amended (the “HSR Act”). The new HSR Act thresholds were published in...more

US NOPEC Developments: Update for National Oil Companies

On Thursday, 7th February, the Judiciary Committee of the U.S. House of Representatives approved the No Producing and Exporting Cartels Act 2019 (NOPEC), potentially setting up a vote by the full House. NOPEC was followed by...more

Executive to Pay Civil Penalties for Not Reporting Compensation Share Acquisition Under HSR Act

A senior executive of a public company has agreed to pay $609,810 in civil penalties for acquiring additional voting securities in the company without first making a Hart-Scott-Rodino Act filing and observing the statutory...more

DOJ Announces Reforms to Merger Review Process

Makan Delrahim, Assistant Attorney General for the U.S. Department of Justice Antitrust Division (“Division”), announced a series of reforms that aim to expedite the Division’s merger review process....more

DOJ Loses First Vertical Merger Suit Brought in Decades as Federal Judge Approves AT&T’s Acquisition of Time Warner

On June 12, 2018, following a six-week-long bench trial, Judge Richard J. Leon of the United States District Court for the District of Columbia ruled that AT&T’s proposed acquisition of Time Warner does not violate the...more

Antitrust Enforcement Under the Trump Administration

Divining trends in antitrust enforcement in a given presidential administration can take some time. Many commentators didn’t notice material changes in antitrust enforcement in the Obama administration – at least in merger...more

The DOJ’s Evolving Approach to Consent Decrees

While structural remedies remain the primary remedy of choice, and virtually the only option in the case of horizontal mergers, under the Obama Administration and with respect to vertical mergers, the agencies increasingly...more

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