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Introduction In the last few years, the European Commission and national competition authorities have demonstrated an increased interest in investigating and punishing gun jumping. This development is part of a broader effort by the Commission to tighten its review of compliance with procedural aspects of the EU’s merger control regime. This increased enforcement is reflected in the staggering €110 million fine imposed on Facebook for providing incomplete and misleading information in connection with its acquisition of WhatsApp, [1] as well as the investigations recently opened against Merck and Sigma-Aldrich and General Electric on the same grounds. [2] As EU law on gun jumping is still not well developed, businesses face increased risk of incurring heavy fines even for inadvertent

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