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Premerger Notifications Enforcement Actions Department of Justice (DOJ)

Jenner & Block

Premerger Enforcement Actions Highlight Importance of HSR Compliance

Jenner & Block on

Cases involving premerger enforcements under the Hart-Scott-Rodino (HSR) Act are relatively rare. So far in 2025, however, we have seen two such cases involving potentially record-breaking penalties. The timing is notable, as...more

Axinn, Veltrop & Harkrider LLP

2023 Merger Guidelines Continue in Effect

In somewhat of a surprise, FTC Chairman Ferguson announced yesterday that the FTC and Department of Justice’s joint 2023 Merger Guidelines “are in effect and are the framework for this agency’s merger-review analysis.” This...more

McCarter & English, LLP

KKR Countersues DOJ for Confusing and Contradictory HSR Rules

Not every investment firm countersues the acting assistant attorney general of the United States for the Antitrust Division, the United States Department of Justice (Antitrust Division), the Federal Trade Commission (FTC),...more

Cadwalader, Wickersham & Taft LLP

DOJ Allegations that KKR Systematically Failed to Comply With the HSR Act – Highlights Importance of DOJ Corporate Compliance...

The Department of Justice (“DOJ”) has alleged in a complaint filed in the Southern District of New York on January 14, 2025 that KKR & Co. Inc. and certain of its investment advisors and funds (collectively, “KKR”)...more

Foley & Lardner LLP

Hart-Scott-Rodino Reporting Threshold Increases by $6.9 Million

Foley & Lardner LLP on

The past two weeks have been quite busy in the world of the Hart-Scott-Rodino Antitrust Improvements Act of 1976 (15 U.S.C. § 18a) (HSR). First, on January 7, 2025, the Federal Trade Commission (FTC) announced a record $5.6...more

Proskauer Rose LLP

FTC Announces 2025 Thresholds Under HSR Act and Clayton Act

Proskauer Rose LLP on

Primary HSR Filing Threshold will be Increased to $126.4 Million - The Federal Trade Commission has announced revisions to HSR Act and Clayton Act Section 8 thresholds, which are indexed annually in alignment with prior...more

Goodwin

DOJ Sues Private Equity Firm KKR & Co. for Violations of HSR Act

Goodwin on

On January 14, 2025, the Department of Justice (DOJ) sued private equity giant KKR & Co. (KKR) for numerous violations of antitrust law, alleging that KKR repeatedly violated its obligations to provide information on its...more

Faegre Drinker Biddle & Reath LLP

New HSR Act Size-of-Transaction Increasing to $126.4 Million

On January 10, 2025, the Federal Trade Commission (FTC) published its adjusted reporting thresholds under the Hart-Scott-Rodino Antitrust Improvements Act of 1976, as amended (HSR Act). The FTC revises the HSR Act thresholds...more

Husch Blackwell LLP

M&A Antitrust Update: 2025 Brings New HSR Thresholds, a Challenge to the HSR Rules, and a Gun-Jumping Violation

Husch Blackwell LLP on

The initial days of 2025 ushered in a trifecta of significant antitrust updates for dealmakers. First, the Federal Trade Commission (FTC) recently announced its annual adjustment to the monetary thresholds that apply to...more

Mayer Brown

M&A Antitrust Alert: FTC Imposes Significant Gun-Jumping Penalty for Unlawful Pre-Merger Coordination Among Crude Oil Producers

Mayer Brown on

M&A practitioners have long regarded the integration planning and execution process as one of the keys to a successful M&A transaction. However, in deals subject to pre-merger antitrust clearance, it is critical to navigate...more

McCarter & English, LLP

FTC Imposes Record $5.6M ‘Gun Jumping’ Fine

Crude oil producers XCL Resources Holdings, LLC (XCL), Verdun Oil Company II LLC (Verdun), and EP Energy LLC (EP) have agreed to pay a $5.6 million civil penalty to settle violations under Section 7A of the Clayton Act, as...more

A&O Shearman

Antitrust in Focus - October 2024

A&O Shearman on

This newsletter is a summary of the antitrust developments we think are most interesting to your business. Roxane Hicheri (counsel based in Paris) and Mark Steenson (counsel based in London) are our editors this month. They...more

Lighthouse

Emerging Trends in Second Requests

Lighthouse on

From increasing regulatory scrutiny to the best way to handle modern attachments, experts share their insights, best practices, and projections to help organizations and law firms prepare for upcoming Second Requests....more

Dorsey & Whitney LLP

Increase in HSR Reporting Thresholds and Filing Fees; Other HSR Developments

Dorsey & Whitney LLP on

In January 2024, the Federal Trade Commission (FTC) made three important announcements for M&A practitioners....more

McDermott Will & Emery

Enforcement Agencies Announce Moratorium on Early Termination Program for Merger Reviews

McDermott Will & Emery on

The US Federal Trade Commission (FTC) released a joint statement with the Department of Justice (DOJ) on February 4, 2021, signaling comprehensive changes to the merger review process. In a significant development, the...more

McDermott Will & Emery

Antitrust M&A Snapshot - February 2021

OCTOBER - DECEMBER 2020 UPDATE - UNITED STATES - Despite initial obstacles because of the COVID-19 pandemic, 2020 rounded out to be the busiest year for mergers and acquisitions (M&A) enforcement in the United States...more

McDermott Will & Emery

Antitrust M&A Snapshot - October 2020

McDermott Will & Emery on

JULY - SEPTEMBER 2020 UPDATE - UNITED STATES- Mergers and acquisitions in the United States appear to be bouncing back after a muted start to the year due to COVID-19. Hart-Scott-Rodino (HSR) filings in Q3 2020 were up...more

Perkins Coie

M&A Corporate Buyer Beware: More Antitrust Challenges to Closed Deals

Perkins Coie on

Despite widespread skepticism that antitrust enforcement would be a Trump administration priority, activity has not lessened. In fact, there has been a substantial increase in challenges to mergers and acquisitions that...more

Proskauer Rose LLP

Expanding HSR Gunjumping Enforcement: Swan Song, or Harbinger of What's to Come?

Proskauer Rose LLP on

In a move that may not have stood up under the new administration, the U.S. Department of Justice Antitrust Division settled a matter during the last days of the Obama Administration which involved allegations of...more

Seyfarth Shaw LLP

Update On Annual Adjustment To HSR Reporting Threshold And Recent Enforcement Actions Against Investors

Seyfarth Shaw LLP on

The Federal Trade Commission (FTC) recently announced that the 2017 size-of-transaction threshold for reporting proposed mergers and acquisitions under Section 7A of the Clayton Act, as added by the Hart-Scott-Rodino...more

Dechert LLP

FTC Raises Maximum Civil Penalty to $40,000; HSR Act and Other Continuing Violations May Incur Civil Penalties of Over $14 million...

Dechert LLP on

Key Points: The FTC is raising the maximum civil penalty that may be imposed for certain violations from $16,000 to $40,000. For HSR Act violations, where penalties may be imposed for each day the person is in...more

Mintz

Investment Fund Violates “Investment-Only” HSR Exemption

Mintz on

At the request of the Federal Trade Commission (“FTC” or “Commission”), the Department of Justice (“DOJ”) filed this week in federal court a proposed settlement to charges that an investment fund violated the...more

Cooley LLP

Alert: HSR "Investment-Only" Exemption: Lessons from Third Point's Yahoo! Investment

Cooley LLP on

While acquisitions of up to 10% of the voting interest in a target that are made "solely for the purpose of investment" are in many circumstances exempt from Hart-Scott-Rodino (HSR) reporting requirements, even when the value...more

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