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On 30 of May 2024 the Council of the European Union adopted the Anti-Money Laundering and Anti-Terrorism Financing Package (the AML Package). The AML Package will have consequences for market parties.

European industry must become less dependent on fossil fuels. To that end, the European Commission now allows state aid to support the transition towards a circular economy.

De Europese industrie moet minder afhankelijk worden van fossiele brandstoffen. De Europese Commissie maakt daarom meer staatssteun mogelijk voor overgang naar een circulaire economie. Tom Barkhuysen, Ali al Khatib en Ramses Walon leggen uit hoe het zit.

The ECJ wrote the epilogue to the Illumina/Grail saga, overturning the EC’s novel ‘Article 22’ approach. It is now clear that the EC cannot accept referral requests to review transactions that fall below the thresholds of national merger control regimes.

M&A transactions falling below the merger notification thresholds are not necessarily exempt from scrutiny. Companies should therefore carefully assess the potential competitive impact of their transactions, as the ACM has proven to be vigilant.

The ECJ overruled the General Court in its CK Telecoms ruling, taking the strict requirements that the GC placed on the Commission when reviewing mergers off the table. This will make it easier for competition authorities to intervene in merger cases.

A potential major overhaul of EU merger control review began on 8 May 2025. Time for stakeholders to speak up about whether and particularly how the European Commission should incorporate wider strategic or societal objectives into its merger assessments.

The countdown is on for digital giants. The entry into force of the Digital Markets Act (DMA) on 1 November 2022 triggered a to do list for potential gatekeepers with 2 May 2023 as the next key date to keep in mind: see our DMA infographic.

The European Commission is on the prowl in the pharma sector. Recent cases on alleged disparagement and pipeline drugs-killings show that it is not afraid to show its teeth and, ultimately, bite.

Companies beware: completed non-notifiable concentrations do not necessarily go scot-free. An ex post abuse-of-dominance investigation by national competition authorities (NCA) could still loom.

2022 marks the second year of the EU Foreign Direct Investment (FDI) Regulation, and the year in which legislators haven been busy shaping the Dutch national security screening regime and the EU Foreign Subsidies Regulation.

2023 marked the near finale of the European Commission’s overhaul of its competition policy, leaving only a few loose ends to tie up in 2024/2025. It is now time to watch theory be put into practice by the competition authorities and at the courts.

Earlier this year, the Foreign Subsidies Regulation (FSR) entered into force to close a loophole in EU regulations aimed at creating a level playing field within the internal market.

The ink on the Digital Market Act has barely dried, but fast-evolving digital developments already have competition authorities calling for new tools. Is Big Tech not kept in check by the DMA, the antitrust rules and the EU Merger Regulation after all?

While 2022 revolved around new and improved regulatory tools, the focus in 2023 will be on putting these tools to use. More merger-related obligations, digital sector scrutiny and clarity on competition-law and consumer-law aspects is imminent.

In April 2024, the European Parliament adopted the EU Listing Act. We discuss the removal of the obligation to immediately disclose an intermediate step in a protracted process that constitutes inside information under the Market Abuse Regulation.

Dutch investment screening is rapidly expanding: since June, the proposal for a separate defence regime has been published and the intended expansion of the regime of the Vifo Act to include AI and biotech has been announced. Reason for a quick update!