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Clifford Chance
Briefings

Briefings

FTC Consent Order Against Beretta Holding Signals Continued Enforcement Focus on Section 8 Interlocking Directorates

September 23, 2026

On September 16, 2026, the US Federal Trade Commission announced a proposed consent order resolving allegations that a proposed share purchase arrangement between firearm manufacturers Beretta and Sturm, Ruger & Co. would create an illegal interlocking directorate in violation of Section 8 of the Clayton Act. The arrangement contemplated Beretta increasing its equity stake in Ruger up to 25% and gaining the right to nominate up to two directors to Ruger's board. The proposed consent order restricts which individuals Beretta may appoint or nominate to Ruger's board, requires Beretta to give the FTC advance notice before selecting any such individual, and limits Beretta's interactions with its nominees following their appointment.

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