EU/UK Competition

The London Antitrust and International Competition team is a trusted advisor to leading multinationals, sovereign wealth funds, global financial institutions and private equity firms on high stakes matters across the full spectrum of ex-US merger control, European Union (EU)/United Kingdom (UK) competition, foreign investment/national security, digital regulation and EU Foreign Subsidies Regulation (FSR) matters. The team has a proven track-record of guiding clients through complex cross-border merger control and foreign investment reviews, abuse of dominance and cartel investigations, state aid issues and landmark competition litigation. Our EU and UK lawyers advise across a wide array of sectors—including technology, communications, aviation, defence, health care, life sciences, automotive, chemicals, transportation, financial services, digital platforms, retail and energy.

• Ex-US merger control – The team is regularly engaged on transactions and reviews that span multiple jurisdictions and regulatory regimes and is known for its ability to coordinate seamlessly with colleagues in the United States and China, as well as local counsel and regulatory authorities across the globe to deliver efficient, pragmatic outcomes. The team advises on complex cross-border mergers, acquisition, joint ventures, strategic investments, co-investments and restructurings, providing scenario-based analysis and structuring advice to navigate regulatory risk and accelerate deal timelines. The team frequently obtains merger control approvals before the UK Competition and Market Authority (CMA), European Commission (EC) and other key global regulators (including in Germany, China, Brazil, Mexico, Canada, India, South Korea, Japan and Australia), and has also advised clients before a number of UK sectoral regulators (including the Financial Conduct Authority (FCA), the Payment Systems Regulator (PSR) and the Water Services Regulation Authority (Ofwat)). The team has also represented interested third parties (including complainants and potential remedy takers) in a number of the most high-profile merger reviews undertaken recently by the EC and CMA.
• EU/UK competition laws – The team’s behavioural and litigation practice is equally robust, with experience advising on investigations into dominant platform conduct, market studies and enforcement actions. It is frequently called upon to represent third parties and complainants in EU/UK behavioural investigations and has experience designing and implementing global competition law compliance programs (including for leading companies in the energy; telecom, media & technology (TMT); financial services; heavy industries; chemicals and health care/pharmaceutical sectors). The team’s experience also extends to the European courts, with recent experience before the Court of Justice of the EU pertaining to refusal to supply and margin squeeze heads of abuse under Article 102 TFEU.
• Foreign investment and national security – The team has represented acquirers, investors and targets on cross-border national security and foreign investment investigations in more than 50 jurisdictions in Europe, Asia, the Americas and Australasia. These investigations have involved targets active in a wide range of sensitive sectors (including artificial intelligence (AI), data infrastructure, energy, military and dual-use, computing hardware, cryptographic authentication and defence). The team has developed a market-leading reputation in the area of national security and foreign investment, particularly under the UK’s National Security and Investment Act (NSIA). It has advised on some of the most significant and precedent-setting matters under the regime, including the first UK judicial review proceeding under the NSIA (heard in July 2024, with judgment handed down in November 2024 (on appeal)) and Final Orders issued by the UK government, as well as in-depth foreign direct investment (FDI) investigations in Germany and France. The team’s ability to draft and negotiate commitments that are accepted without amendment reflects its deep understanding of the policy and enforcement landscape.
• Digital regulation – The team is at the forefront of regulatory developments, advising on behavioural investigations, digital platform regulation and the application of emerging frameworks such as the EU Digital Markets Act and the UK’s Digital Markets, Competition and Consumers (DMCC) regime. The team also co-leads the firm’s AI practice, advising on the competition law implications of AI development and deployment, including issues related to interoperability, data access and market power.
• EU Foreign Subsidies Regulation (FSR) – The team has significant experience representing acquirers and targets in investigations pursuant to the EU FSR, and counselling large private equity firms and sovereign wealth funds on EU FSR compliance.

In each of the above areas, the team focuses on combining technical excellence, commercial insight and a collaborative approach, both within the firm and with external stakeholders, to ensure that clients receive tailored, high-impact advice on their most complex and sensitive matters.

Representative Matters

Merger Control

• Advised LetterOne in the $11.2 billion reverse takeover of Harbour Energy PLC.
• Acted for a remedy-taker in the CMA’s in-depth Phase 2 merger investigation of the £16.5 billion merger of Vodafone and Three (UK).
• Representing a United Arab Emirates (UAE) investor in the c. $24 billion take-private of Wallgreens Boots Alliance (WBA).
• Represented a leading global private equity house on its $4.4 billion acquisition of GDS Travelport and $3 billion acquisition of Cubic Corporation.
• Represented the Abu Dhabi Investment Authority (ADIA) in its c. $14 billion acquisition of McAfee Corp. as part of a consortium including Advent International, Permira, Crosspoint, GIC and CPPIB.
• Acted for Vitol in its $2.3 billion public takeover of Vivo Energy.
• Advising Energy Equation Partners and Stonepeak in their €2.5 billion acquisition of a majority interest in JET Tankstellen Deutschland GmbH from Phillips 66.
• Represented TGS ASA in the c. $2 billion takeover of listed peer PGS ASA.
• Represented Macquarie and Siemens in the creation of Calibrant JV, which originates, operates and finances energy-as-a-service (EaaS) projects.
• Represented Olin Corp. in its strategic Blue Water Alliance joint venture with Mitsui & Co.
• Advised a selling shareholder in the context of SABIC’s $2.4 billion acquisition of a large minority stake in Clariant.
• Representing numerous financial institutions/funds in the competition law and regulatory implications of the restructuring of Thames Water.
• Represented an interested party in multiple merger investigations into Microsoft’s $69 billion acquisition of Activision Blizzard.
• Representing Apollo Global Management Inc. in the Chapter II bankruptcy (including $700 million debtor in possession (DIP) finance facility) and restructuring of Scandinavian Airlines (SAS).

National Security, Foreign Investment & Foreign Subsidies

• Representing LetterOne in one of the first retroactive call-ins under the UK National Security & Investment Act and negotiating undertakings with the Secretary of State in relation to the target, Upp.
• Representing LetterOne in the first judicial review under the UK National Security & Investment Act in the High Court (on appeal).
• Advising a global private equity house on all aspects of EU Foreign Subsidies Regulation (FSR) compliance and investment strategy.
• Represented Nexperia B.V. on the $177 million sale of Newport Wafer Fab to Vishay Intertechnology Inc.
• Counselling a global defence company on supply and procurement contracts.
• Advising a UK housebuilder on UK subsidies regulation.
• Advised 80 financial institutions holding c. $33 billion in bonds in the restructuring of the Icelandic banks, including advising on state aid.