The Antimonopoly Committee of Ukraine (AMC) is increasing enforcement efforts against so-called “gun-jumping” violations (i.e. a merger or acquisition executed without the prior approval of the AMC), demanding stricter scrutiny even for transactions with a perceived limited impact on the Ukrainian market. Between January 2022 and October 2024, the AMC imposed not only fines on companies that failed to obtain a prior clearance, but also on those that sought approvals after already closing their deals.
To avoid penalties, companies must ensure they have secured AMC clearance before closing transactions, as even war-related challenges do not exempt firms from compliance requirements.
Kinstellar’s Ukraine Competition & State Aid team has conducted an in-depth analysis of all gun-jumping cases from January 2022 to October 2024, uncovering key enforcement trends by the Antimonopoly Committee of Ukraine (AMC). The exclusive summary table highlights the most notable cases, including resulting in hefty fines that reach hundreds of thousands of euros. For those seeking a deeper dive, the full summary table is available upon request.
