China's Simplified Merger Review Program May Significantly Reduce Wait Times for Certain Global Transactions

• MOFCOM announces simplified merger-review program that could accelerate antitrust clearance from Chinese authorities for many transactions. MOFCOM estimates as many as 60% of notified transactions will qualify and receive clearance in Phase I (within 30 days).
• The simplified procedure will be available to transactions unlikely to raise competitive concerns, such as horizontal transactions resulting in less than a 15% market share; vertical and conglomerate transactions resulting in less than a 25% market share; and foreign transactions with no domestic effect in China.

On February 12, 2014, China's Ministry of Commerce ("MOFCOM") announced the implementation of its simplified merger-review program. Similar to the EU's "Short Form CO," under the new rules, transactions meeting certain thresholds will qualify for a so-called "fast track." MOFCOM has estimated that it could clear as many as 60 percent of notified transactions within Phase I (i.e., within