UAE Competition Law Update: Consequences For M&A Transactions In The UAE

The United Arab Emirates ("UAE") recently introduced its competition law: Federal Law No. 4 of 2012 ("Competition Law"). In February 2013, we published a Commentary on this law, noting that it was the first of its kind to regulate anticompetitive behavior and monopoly practices in the UAE. We also noted that the Competition Law remained silent as to critical issues such as threshold and procedural requirements. The UAE Cabinet now has issued implementing regulations, Cabinet Decision No. 37 of 2014 (the "Regulations"). While these Regulations provide new clarity on the applicable exemption/clearance procedures, there remain significant gaps in its explanation of how the Competition Law will operate.