China’s antitrust regulators have published revised drafts of three implementation rules explaining aspects of the enforcement approach that will be applied to key Anti-Monopoly Law (“AML”) ‘conduct rule’ prohibitions.

Public consultation is continuing in relation to these drafts, and while this process continues it is expected that regulatory enforcement of the conduct rules will remain limited. However, the drafts may impact the approach China’s courts take to AML private action cases (which are progressing, notwithstanding the lack of regulatory enforcement) and the latest changes to the drafts reveal new insights into the enforcement approach and methodology that may eventually be adopted by China’s Anti-Monopoly Enforcement Authorities.

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