On August 28, 2018, the FCC’s Enforcement Bureau announced a Consent Decree with Marriott International, Inc. (“Marriott”) to resolve an investigation into unauthorized transfers of wireless radio licenses in connection with Marriott’s acquisition of Starwood Hotels & Resorts Worldwide Inc. (“Starwood”). The civil payment levied against Marriott and the other conditions set forth in the Consent Decree serve as a reminder to companies that may not normally be subject to the FCC’s jurisdiction to thoroughly review the regulatory implications of mergers, acquisitions, or other corporate transactions as part of any due diligence conducted before a deal is reached.

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