FAS Russia Publishes Merger Control Guidelines

The Federal Antimonopoly Service (FAS Russia) has published merger control guidelines¹ (the "Guidelines"). This is the first time over the fifteen-year existence of the modern Competition Law² that the service has published guidelines of such scope and depth in this area. The document not only summarizes the decade and a half of the antimonopoly authority's practice of considering mergers, but also provides insight into the regulator's position on a number of questions for which the laws and regulations did not give straightforward answers. Parties would ask the regulator to clarify them on a case-by-case basis,³ but those clarifications were not always consistent. Or, parties had to rely on common sense and the overall logic of the Competition Law to interpret the unclear provisions.