2019 marked the eleventh anniversary of China’s Anti-Monopoly Law, which takes several noteworthy steps to refine and streamline antitrust enforcement in China. The arrival of the first AML amendments and regulations may help clarify expectations for companies operating in China, though certain key deviations from Western antitrust enforcement remain. While Chinese review of significant transactions continues to be lengthy, the review for more straightforward transactions—which comprise the vast majority of transactions—has become quicker and more streamlined, particularly for U.S. companies. At its core, even as China appears to find efficiency gains in quicker merger review, certain causes of action (such as “excessive pricing”) and remedies continue to differ from the types of remedies imposed by Western authorities.

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