The HSR Act enables antitrust regulators to review transactions, investigate and address potential competitive concerns prior to completion, and carries annually adjusted monetary penalties for failure to comply – presently set at $43,792 per day. The requirement can sometimes become a trap for investors – not realizing that filing requirements under the HSR Act may apply in unexpected contexts, including acquisitions of minority holdings. It has been the unwritten policy of the agency for some time to exercise its prosecutorial discretion and not impose penalties for first time inadvertent failures to file, but to act more firmly in the case of repeat offenders, even where inadvertent.