2020 marked the twelfth anniversary of China’s Anti-Monopoly Law.  Over the course of the past year, the Chinese authorities made it clear that they expect to be full participants in the ongoing international dialogue regarding competition enforcement and policy for internet platforms, both with respect to mergers and business conduct in the digital realm.  The past year also saw potentially significant changes in Chinese antitrust enforcement activity, with the highest-ever monetary penalties imposed and high-profile enforcement actions targeting internet platform operators.  The State Administration for Market Regulation published Draft Anti-Monopoly Guidelines on the Sector of Platform Economies, which may well lead to increased scrutiny of mergers by internet platforms—particularly of smaller or “nascent” competitors.  The Draft Guidelines also highlight concerns about exclusionary provisions related to online sales.

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