Alexandra Rogers
Alexandra is a dual qualified (EU/UK) competition lawyer and Head of the Norton Rose Fulbright Brussels office. She advises clients on a broad range of EU and national law issues, including cross-border merger control, dawn raids and investigations, and competition and regulatory compliance. She has represented companies and trade associations in an array of sectors including energy, telecommunications, technology, consumer goods/manufacturing and banking as well as private equity firms.
Alexandra regularly supports clients in merger control proceedings before the European Commission and the UK competition authority, including in complex cases requiring divestitures. She is also a core member of the NRF team assisting clients to comply with the EU Foreign Subsidies Regulation.
Alexandra has a significant track record of defending and advising clients in major international cartel investigations in areas such as power cables, ball bearings and Euribor derivatives. Her experience also includes handling litigation before the EU Courts as well as defending follow-on damages actions in various EU Member States.
Practice Area
Panel
- Contributing Author
Qualified Year
- England & Wales (2007); Belgian Bar (2017)
Experience
- White & Case (September 2008 - July 2022)
Qualifications
- Solicitor of England & Wales (2007)
- Avocat, Barreau de Bruxelles, Belgium (2017)
Education
- College of Europe (Bruges) LLM (2007-2008)
- College of Law (Chester), LPC (2004-2005)
- University of Durham, LLB (2000-2004)
2 Contributions by Alexandra Rogers
PRACTICE NOTES
EU Foreign Subsidies Regulation: Public Procurement Notifications and Declarations - Scope, €250m/€4m Thresholds, FS-PP Requirements, Review Timelines and Commission Powers
On 12 January 2023, Council Regulation (EU) 2022/2560 of 14 December 2022 on foreign subsidies distorting the internal market (FSR) took effect. On 10 July 2023, the European Commission adopted Council Regulation (EU) 2023/1441 of 10 July 2023 on detailed arrangements for the conduct of proceedings by the Commission pursuant to Regulation (EU) 2022/2560 of the European Parliament and the Council on foreign subsidies distorting the internal market (Implementing Regulation), which sets out the procedural rules for putting the FSR into practice. The FSR establishes a new system designed to address distortions to competition in the EU internal market stemming from foreign subsidies. It introduces compulsory notification and clearance duties for substantial EU public tenders and for takeovers of significant EU businesses, and grants the Commission broad powers to commence ex officio inquiries. The notification obligations have applied since 12 October 2023.
Mandatory notification/declaration for public procurement procedures
Public procurement procedures fall within the FSR notification regime when the following conditions (1–3) are all met. If only the first two conditions are satisfied, economic operators must submit a declaration. In an open (single-stage) procurement procedure, the notification or declaration must be provided once, alongside the tender. In a...
Competition
PRACTICE NOTES
EU Foreign Subsidy Regulation Concentration Notifications, Turnover and FFC Thresholds, Form FS-CO, Reporting Duties, Balancing Test, Review Timelines, Standstill, and Commission Investigatory Powers
On 12 January 2023, Council Regulation (EU) 2022/2560 of 14 December 2022 on foreign subsidies that distort the internal market (the FSR) came into effect.
On 10 July 2023, the European Commission (Commission) adopted Council Regulation (EU) 2023/1441, the Implementing Regulation, which lays down detailed arrangements for how the Commission conducts proceedings under Regulation (EU) 2022/2560 of the European Parliament and of the Council on foreign subsidies distorting the internal market, setting out procedural rules for putting the FSR into practice.
The FSR establishes a new framework to tackle distortions of competition within the EU internal market arising from foreign subsidies. It introduces mandatory notification and clearance obligations for takeovers of significant EU businesses and for sizeable EU public procurement, and grants the Commission wide-ranging powers to open ex officio inquiries. The notification obligations have applied since 12 October 2023.
This Practice Note summarises the principal aspects of the FSR, including the compulsory notification and approval regime for M&A deals and the Commission’s capacity to initiate its own investigations into problematic foreign subsidies.
Notification obligation for concentrations
M&A transactions are notifiable under the FSR where the below conditions are met...
Competition
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