The FTC has secured what it says is the largest civil penalty ever obtained for a Hart-Scott-Rodino filing failure: a combined $12 million settlement with Edwards Lifesciences and Genesis MedTech over the acquisition of JC Medical. According to the agency, the companies structured the transaction to avoid premerger notification and waiting-period requirements under the HSR Act, prompting an enforcement action filed in the U.S. District Court for the District of Columbia by the DOJ on the FTC’s behalf.

That headline number matters.