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State-Level Merger Control Grows: California Joins “Mini-HSR” Trend with Senate Bill 25

By Charlene Sun, Megan L. Wolf, Daniel Leff & Angel Prado on February 24, 2026
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On February 10, 2026, California enacted Senate Bill 25 (“SB 25”), known as the California Uniform Antitrust Pre-Merger Notification Act. The new law takes effect on January 1, 2027, making California the third state—following Washington (effective July 27, 2025) and Colorado (effective August 6, 2025)—to implement a “mini-HSR” regime modeled after the Uniform Antitrust Pre-Merger Notification Act (“UAPNA”). The legislation reflects the growing state-level focus on merger oversight, and it signals California’s continuing intent to increase early pre-merger scrutiny and concurrent review of transactions with federal authorities. Click here to continue reading the full version of this alert.

Photo of Charlene Sun Charlene Sun
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Photo of Megan L. Wolf Megan L. Wolf

Megan Louise Wolf is a partner in the firm’s Washington, D.C. office. Megan’s practice focuses on antitrust counseling, mergers and acquisitions, and criminal and civil antitrust investigations. Named as a “Rising Star” by Legal 500 and The Deal, Megan counsels and represents…

Megan Louise Wolf is a partner in the firm’s Washington, D.C. office. Megan’s practice focuses on antitrust counseling, mergers and acquisitions, and criminal and civil antitrust investigations. Named as a “Rising Star” by Legal 500 and The Deal, Megan counsels and represents clients in a wide range of transactional antitrust matters, including mergers and acquisitions, joint ventures, competitor collaborations, and issues related to compliance with the Hart-Scott-Rodino Antitrust Improvements Act. Megan represents corporate clients and individual executives in criminal antitrust investigations, including those into procurement fraud, hiring practices, financial services, generic pharmaceuticals, and numerous other industries.

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Photo of Daniel Leff Daniel Leff

Daniel Leff is an antitrust litigator, trial lawyer, and strategic advisor. As a former state assistant attorney general, he draws on his experience litigating complex, high-profile antitrust cases for clients involved in or anticipating litigation as both plaintiffs and defendants. Dan also counsels

…

Daniel Leff is an antitrust litigator, trial lawyer, and strategic advisor. As a former state assistant attorney general, he draws on his experience litigating complex, high-profile antitrust cases for clients involved in or anticipating litigation as both plaintiffs and defendants. Dan also counsels and advocates for companies seeking antitrust regulatory approval for mergers, acquisitions, and innovative business deals.

Dan joined Crowell from the Massachusetts Attorney General’s Office (AGO), where he served in the Office’s Antitrust Division. In that role, he worked hand-in-hand with enforcers from the U.S. Department of Justice (DOJ), the Federal Trade Commission (FTC), and the attorney general offices of nearly every U.S. state and territory to investigate and litigate merger, monopolization, and cartel matters.

His work with the AGO included successfully trying merger and Sherman Act § 1 cases in federal court. He was also a lead member of a plaintiff group comprising nearly every state attorney general office in the country in a large pharmaceutical price-fixing multidistrict litigation (MDL).

Dan also investigated, litigated, and settled numerous competition matters in industries including telecommunications, transportation, energy, agricultural products, healthcare, and pharmaceuticals. Clients benefit from Dan’s experience in the Sherman, Clayton, and FTC acts and numerous state antitrust and consumer protection statutes, as well as his familiarity with the perspectives of state and federal enforcers across the country.

Dan began his career at Crowell, where he represented clients facing federal and state antitrust, consumer protection, and environmental scrutiny, primarily in the telecommunications and energy industries. He also previously worked for an international law firm in Boston, representing pharmaceutical and medical device companies facing federal civil and criminal investigations.

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  • Posted in:
    Antitrust, Competition and Trade
  • Blog:
    State AG Blog
  • Organization:
    Crowell & Moring LLP
  • Article: View Original Source

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