Due to the introduction of martial law in Ukraine on 24 February
2022, the operations of the Antimonopoly Committee of Ukraine (AMC)
have been adjusted or suspended in a number of ways. As a result,
on 30 March 2022 the AMC adopted Guidelines on the filing and
consideration of applications for merger clearances and concerted
actions during martial law (Guidelines).
To remind, Ukrainian competition legislation has exterritorial
effect, meaning that concentrations finalised outside Ukraine may
require approval from the AMC, if the financial thresholds provided
under Ukrainian law are exceeded.
Below we provide important highlights from the
Guidelines with respect to merger and concerted action controls
during martial law in Ukraine. Please note that martial law has
been introduced in Ukraine until 25 April 2022 but may be further
extended.