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ARTICLE · 04 MARCH 2026

The Toll Of Non-compliance: Procedural Merger Control Violations Trigger Record Sanctions

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Fines for breach of procedural merger control rules surged in 2025. Once again, the U.S. led the charge, imposing record penalties. In China, geopolitical factors played a role in some infringement investigations.

GlobalAntitrust/Competition Law
Dominic Long
Dominic Long
Noah Brumfield
Noah Brumfield
Peter McDonald
Peter McDonald
Francesca Miotto
Francesca Miotto
Louise Tolley
Louise Tolley
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Fines for breach of procedural merger control rules surged in 2025. Once again, the U.S. led the charge, imposing record penalties. In China, geopolitical factors played a role in some infringement investigations. Overall, merging parties should be on notice that antitrust authorities are taking a zero-tolerance approach to enforcement. 

Total fines split by fine type (USDm)

1752518a.jpg

Antitrust authorities imposed total fines of USD62.7 million in 2025 across the jurisdictions surveyed.

This is a significant increase. While the total number of decisions (39) was slightly lower than in 2024 (42), overall penalty levels more than doubled.

U.S. gun-jumping fine smashes ceiling 

Penalties for deals implemented before the conclusion of a merger review process continued to make headlines.

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