Yes — closing without clearance and early exercise of control are subject to turnover-based administrative fines. An interim-period conduct guide and a clean team protocol should be in the deal team’s hands from day one.
The fine is not abstract: the Law on the Protection of Competition (No. 4054) provides for an administrative fine calculated on the parties’ turnover for the previous year where a merger or acquisition is completed without clearance. There is a structural consequence on top of it — the transaction stays legally suspended until clearance, so steps taken in the meantime can be unwound. Waiting for closing is not a tactic; it is the rule. The interim guide and clean-team protocol are what keep the deal team on the right side of that line.
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