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Antitrust M&A Snapshot

Antitrust M&A Snapshot | Q4 2025

October – December 2025: Key themes and takeaways

The fourth quarter of 2025 saw notable developments in antitrust M&A enforcement across major jurisdictions. In the United States, courts delivered multiple setbacks to the Federal Trade Commission (FTC), rejecting narrow market definitions and vertical foreclosure theories, while accepting party‑proposed remedies as adequate solutions. The FTC adjusted its enforcement approach by moving away from parallel administrative actions and focusing instead on challenges in federal court. State attorneys general increased their involvement in merger reviews, intervening in a high-profile federal settlement in light of perceived improper lobbying influence.

In the European Union, the European Commission cleared complex transactions through early engagement with merging parties, including deals involving supplier power and market consolidation. The United Kingdom’s Competition and Markets Authority implemented new remedy guidelines emphasizing pace, predictability, proportionality, and process, with greater flexibility for behavioral remedies and pre‑notification discussions. Together, these developments reflect evolving enforcement priorities and approaches across jurisdictions.

In this edition of Antitrust M&A Snapshot, we provide an in‑depth analysis of these trends and their potential impact on future transactions.

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Key contacts

McDermott Will & Schulte’s global competition practice can assist clients with antitrust M&A issues in various jurisdictions around the world. Feel free to contact one or more of our partners in our various offices. The individuals below can assist or can refer you to one of our many other lawyers in our competition team who can help with a specific question.