July 7, 2016
HSR Violation Penalties More Than Doubled by FTC
Last week, as noted in these memos, the Federal Trade Commission announced an increase in the maximum civil penalties it may impose for violations of the Hart-Scott-Rodino Act and various other rules and orders governed by the FTC. The maximum civil penalty for HSR violations has increased from a daily fine of $16,000 per day to $40,000. While these higher maximum civil fines will apply to any penalties assessed after August 1st, they will also apply to violations that predate the effective date…