On 1 October 2019, the Indonesian Competition Commission,
Komisi Pengawas Persaingan Usaha (KPPU)
imposed a record-breaking fine of IDR20.66 billion (approx. USD1.46
million) on PT Citra Prima Sejati (CPS) for its
failure to notify the KPPU of two transactions within the required
timeframe. These transactions involved CPS's acquisition of two
Indonesian mining companies, PT Buana Minera Harvest and PT Mitra
Bisnis Harvest, on 24 December 2013
(Transactions).
The record-breaking sanction
These fines arise in part as a result of the KPPU's
systematic review of previous transactions that had failed to be
notified to the KPPU, as we previously reported (link). The Indonesian Merger Control
Rules require companies to notify the KPPU of any mergers,
consolidations, or acquisitions (Mergers) that
meet certain criteria 1 within 30 business days since
the Mergers become legally effective. The KPPU decided that both
CPS Transactions met these criteria, such that CPS ought
