News & Analysis as of

Acquisition Agreements Enforcement Actions

Troutman Pepper Locke

M&A and Global Compliance Lessons From OFAC’s Settlement With Key Holding

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On July 2, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) reached a settlement with Key Holding, LLC (Key Holding) concerning its non-U.S. subsidiary’s violations of the Cuban Assets...more

Quarles & Brady LLP

DOJ Uses Successor Liability as a Civil Cybersecurity Enforcement Tool: Comprehensive Diligence Now May Save Millions Later

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The United States Department of Justice (DOJ) recently settled a qui tam suit with a defense contractor and its successor company for $8.4 million, resolving allegations that the contractor and successor company violated the...more

Quarles & Brady LLP

DOJ’s Civil Cyber Fraud Initiative Utilizes False Claims Act to Settle Allegations of Knowing Non-Compliance with NIST SP 800-171...

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The United States Department of Justice (DOJ) recently settled a qui tam suit with defense contractor Raytheon and its successor company, Nightwing Intelligence Solutions, LLC (Nightwing), totaling $8.4 million. The...more

Jones Day

Landmark European Commission Cartel Fines on No-poaching Agreements and Minority Shareholdings

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European Commission ("EC") issues its first fining decision for a no-poach agreement, and also sanctions for the first time the exchange of sensitive information between a company and its competing, non-controlling minority...more

Dacheng

China Monthly Antitrust Update: May 2025

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This monthly report outlines key developments in China’s antitrust sector for May. The following events merit special attention...more

Dacheng

China Monthly Antitrust Update: April 2025

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This monthly report outlines key developments in China’s antitrust sector for April. The following events merit special attention...more

Seyfarth Shaw LLP

Federal Trade Commission Antitrust Roundup: Trump Administration Off to An Aggressive Start

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Last week, on April 10, 2025, the U.S. Senate confirmed Mark Meador as the FTC’s third Republican commissioner.  Meador joins Chairman Ferguson and Commissioner Melissa Holyoak on what is now a three commissioner panel (all...more

Dacheng

China Monthly Antitrust Update: March 2025

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This monthly report outlines key developments in China’s antitrust sector for March. The following events merit special attention...more

DLA Piper

FTC signals continuation of rigorous approach to merger enforcement

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Recently appointed Federal Trade Commission (FTC) Chairman Andrew Ferguson affirmed last week in a memorandum to FTC staff that the 2023 Merger Guidelines will remain in effect for the foreseeable future. This decision aligns...more

Quarles & Brady LLP

PE in Healthcare – Recent Governmental Commentary Could Indicate Policy Changes on the Horizon and Time for Increased Vigilance

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Recent reports published by the Senate Budget Committee (the “Committee”) and the U.S. Department of Health and Human Services (“HHS”) highlight what the authors characterize as concerns related to private equity (“PE”)...more

Jones Day

China Unveils New Anti-Monopoly Guidelines for the Pharmaceutical Sector

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China's State Council issued new Anti-Monopoly Guidelines for the Pharmaceutical Sector (the "Guidelines") effective January 24, 2025. The Guidelines provide a comprehensive framework for the State Administration for Market...more

Jones Day

FTC Imposes Record Fine on Texas Energy Companies for HSR "Gun Jumping"

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During antitrust review between M&A signing and closing, HSR rules restrict an acquiror from beginning to control the target's business....more

Troutman Pepper Locke

FTC Takes Another Shot at Private Equity Roll-Ups

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At the end of the Biden administration, the Federal Trade Commission (FTC) announced a settlement with private equity firm Welsh, Carson, Anderson, and Stowe, and several of its affiliates (Welsh Carson), resolving what the...more

The Volkov Law Group

C.H. Robinsom Settles with OFAC for $257,690 to Resolve Iran and Cuba Sanctions Violations

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C.H. Robinson International Inc. (CHR), a Minnesota-based global transportation and logistics company, has agreed to pay $257,690 to settle civil liability for 82 apparent violations of sanctions against Iran and Cuba...more

DLA Piper

FTC Assesses Record Fine for Gun-Jumping Antitrust Violation

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The Federal Trade Commission (FTC) announced, on January 7, 2025, that crude oil producers agreed to pay a record $5.6 million fine as settlement for violating the Hart-Scott-Rodino Act (HSR Act) through illegal pre-merger...more

Troutman Pepper Locke

FTC Secures Record Gun-Jumping Settlement in Energy Transaction

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The Federal Trade Commission (FTC) and the Department of Justice, Antitrust Division (DOJ) announced a record-setting $5.6 million gun-jumping fine related to Verdun Oil Company II LLC’s acquisition of EP Energy LLC. Although...more

Ballard Spahr LLP

Record $5.6 Million Penalty for 'Gun-Jumping' Violation

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The Federal Trade Commission (FTC) announced a record $5.6 million civil penalty to settle allegations that three crude oil producers engaged in “gun-jumping” activities that violated the Hart-Scott-Rodino (HSR) Act....more

Thomas Fox - Compliance Evangelist

Deere FCPA Enforcement Action: Lessons on Post-Acquisition Integration and Investigation in M&A

We recently had a Foreign Corrupt Practices Act (FCPA) enforcement action that reminded me that everything old is new again in anti-corruption compliance. The Securities and Exchange Commission (SEC) FCPA enforcement action...more

The Volkov Law Group

Deere’s Bribery Schemes — Circumventing Expense Controls (Part II of II)

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The Deere case is an important reminder for companies to devote proper attention to ensuring robust integration planning for acquired companies.  DOJ has provided important guidance on acquisition practices and the need to...more

Baker Botts L.L.P.

DOJ Obtains $3.5 Million Civil Penalty and Appoints Antitrust Compliance Officer to Resolve Gun-Jumping Concerns

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On August 5, the Department of Justice (DOJ) secured a landmark decision from the U.S. District Court for the District of Columbia in a high-profile monopolization litigation....more

Vinson & Elkins LLP

Gun-Jumping Isn’t the Stuff of Legends: DOJ Fines Hospitality Management Company $3.5 Million for Alleged Unlawful Pre-merger...

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On August 5, 2024, the Department of Justice (“DOJ”) announced that it filed a civil complaint and proposed settlement with Legends Hospitality Parent Holdings LLC (“Legends”) for unlawful pre-merger coordination, commonly...more

Troutman Pepper Locke

PE Firm Escapes FTC’s Challenge to Texas Anesthesiology Roll-Up

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A Texas federal court dismissed the Federal Trade Commission’s (FTC) lawsuit against private equity (PE) owner, Welsh, Carson, Anderson & Stowe (Welsh Carson), while allowing to proceed the agency’s challenge against U.S....more

Mayer Brown

Private Equity Roll-Ups: Court Dismisses Welsh Carson from Roll-Up Litigation

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The Federal Trade Commission’s (FTC) push against private equity roll-ups has hit a snag. On May 14, 2024, US District Judge Kenneth Hoyt of the Southern District of Texas granted a motion to dismiss filed by Welsh, Carson,...more

Jones Day

SEC Prevails in Novel "Shadow Trading" Insider Trading Trial

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The Securities and Exchange Commission ("SEC") won at trial in its first "shadow trading" case, holding a corporate official liable for insider trading for using nonpublic information about his company's acquisition to trade...more

Cornerstone Research

Trends in Merger Investigations and Enforcement at the U.S. Antitrust Agencies: Fiscal Years 2005-2022

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In fiscal year 2022, merger transactions and second requests decreased from the prior year....more

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