Top Insights for Dealmakers From a Year of EU Foreign Subsidies Regulation Filings

One year since the commencement of notification obligations under the European Union’s Foreign Subsidies Regulation (FSR), we summarise key takeaways for dealmakers. Enforcement action to date has predominantly focused on public procurement tenders rather than M&A, with Chinese, state-owned enterprises and sovereign wealth funds attracting the most scrutiny. Early indications are that the EC is open to accepting commitments as opposed to pursuing outright prohibitions, though disclosure obligations can be extensive.

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