Authors: Han Kun Law Offices Chen Ma丨 Da Shi丨Jiahao GuoKey Takeaways from the Revision Draft:Holds liable undertakings organizing or assisting the reaching of a monopoly agreement in the same manner as participants in the monopoly agreement.Introduces the indispensability test in addition to other tests to qualify for a monopoly agreement exemption, could further increase the difficulty in applying for exemptions.Grants SAMR the right to adjust Merger filing thresholds to adapt to market changes.Highlights Authenticity of submitted documents and materials, fines rise substantially for fraudulent materials or information.Introduces Stop-clock rules for merger reviews, which could replace the current practice of withdrawal and refiling upon expiry of the 180-day statutory time limit.Increases maximum fines to RMB 50 million in cases where cartels are reached bu
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