Antitrust Agency Insights: Developments At The U.S. Antitrust Enforcement Agencies — First Quarter 2025

Letter From the Editors

After a flurry of antitrust activity from the U.S. Federal Trade Commission (FTC or the Commission) and the Antitrust Division of the U.S. Department of Justice (DOJ Antitrust) in the waning days of the Biden administration, the second Trump administration has raced out the gates with its own burst of activity. The full scope of the antitrust agencies' enforcement and policy priorities remains to be seen, but the first two months of the second Trump administration have given us some insight into the antitrust agencies' priorities and areas to watch closely going forward.

• Merger review process, including the availability of remedies. We expect the agencies' vigorous merger investigations and enforcement actions to continue, focused more closely on traditional antitrust theories of harm. The agencies affirmed that the 2023 Merger Guidelines, which (among other things) lowered the thresholds under which they will assert a merger is