Sangbum Ro


There has been a significant increase in the merger of conglomerates and multi-national companies worldwide. This trend has raised many concerns about antitrust and competition laws. This paper undertakes a comparative analysis of merger regulations in 4 countries – Korea, Japan, the United States, and the European Union. The author also discusses the development of competition laws that guide merger transactions in these countries. The paper explores political and economic ideologies that drive the differences in merger regulations in these 4 countries. The paper concludes with the proposition for a uniform merger regulation or treaty in cross-border transactions.