ARTICLE
27 March 2026

“Gun-jumping” In Ukraine: 2022-2025 Enforcement Dynamics

K
Kinstellar

Contributor

Kinstellar acts as trusted legal counsel to leading investors across Emerging Europe and Central Asia. With offices in 11 jurisdictions and over 350 local and international lawyers, we deliver consistent, joined-up legal advice and assistance across diverse regional markets – together with the know-how and experience to champion your interests while minimising exposure to risk.
Over the past four years, the Antimonopoly Committee of Ukraine ("AMC") has significantly intensified enforcement against so-called "gun-jumping" violations, in which mergers or acquisitions occur prior to obtaining AMC approval.
Ukraine Antitrust/Competition Law
Kinstellar are most popular:
  • within Antitrust/Competition Law, Insurance and Consumer Protection topic(s)

March 2026 – Over the past four years, the Antimonopoly Committee of Ukraine ("AMC") has significantly intensified enforcement against so-called "gun-jumping" violations, in which mergers or acquisitions occur prior to obtaining AMC approval. This trend is reflected not only in the growing number of cases, but also in the evolution of the AMC’s approach to investigations, fine calculation and substantive assessment.

To avoid penalties, companies must ensure they secure AMC clearance before closing transactions, as even war-related challenges do not exempt firms from compliance requirements.

Our Ukraine Competition & State Aid team has conducted an in-depth analysis of all gun-jumping cases from January 2022 to December 2025, uncovering key enforcement trends by the Antimonopoly Committee of Ukraine (AMC). Our exclusive summary table highlights the most notable cases, including those resulting in hefty fines that reach hundreds of thousands of euros. For those seeking a deeper dive, the full summary table is available upon request.

Click on the image below or use the following link to read our overview in English.

1765748a.jpg

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

[View Source]

Mondaq uses cookies on this website. By using our website you agree to our use of cookies as set out in our Privacy Policy.

Learn More