FTC Imposes Record Gun‑Jumping Fine Of $5.6M

January 27, 2025 – On Jan. 7, the Federal Trade Commission announced the imposition of a $5.6 million fine for a gun-jumping violation under the Hart-Scott-Rodino Antitrust Improvements Act of 1976 (HSR Act). Gun-jumping violations occur when parties to a potential transaction inappropriately begin to integrate their operations or otherwise prematurely implement the transaction prior to receiving regulatory antitrust clearance.¹ The fine is the result of a settlement with crude oil producers XCL Resources Holdings, LLC, Verdun Oil Company II LLC, and EP Energy LLC. The $5.6 million penalty is the largest ever imposed for a gun-jumping violation in the United States, and serves as a reminder of the critical importance of refraining from premature coordination during the HSR Act waiting period.