Very significant fines have been levied for procedural breaches of the merger rules in the last year or so. Facebook was fined €110 million in 2017 for providing misleading information and Altice was fined €125 million in 2018 for gun-jumping. The European Commission (EC) has gotten much tougher on procedural violations of the merger control rules. But it’s not just the EC. The U.S. agencies have also continued to penalize gun-jumping heavily, and several other antitrust authorities across the world are following suit.

Read this chapter in Shearman & Sterling’s 2019 Antitrust Annual Report, “Tougher Implementation of Procedural Rules in Merger Control.”