Michael Knight

Annual revisions to U.S. merger notification thresholds and increased filing fees are expected to take effect in February 2026. Interlocking Directorates thresholds also increase. The Federal Trade Commission ("FTC") announced on January 14, 2026, that the Hart-Scott-Rodino ("HSR") Act filing thresholds will once again increase. These thresholds determine which mergers and acquisitions must be reported to the federal government before consummation.

JD Jones Day More Jones Day is a global law firm with more than 2,500 lawyers across five continents. The Firm is distinguished by a singular tradition of client service; the mutual commitment to, and the seamless collaboration of, a true partnership; formidable legal talent across multiple disciplines and jurisdictions; and shared professional values that focus on client needs. "Gun jumping" is an enforcement priority for the Department of Justice and Federal Trade Commission.

In Short The Rule: During antitrust review between M&A signing and closing, HSR rules restrict an acquiror from beginning to control the target's business. Enforcement: Government is closely watching transaction parties' adherence to gun-jumping rules. This new action led to a significant fine for pre-closing conduct, including allegations of early control of the target; aggressive pre-closing covenants; and loose information sharing.