Analyzing Spain’s New Corporate Compliance Defense

Spanish criminal law now includes an affirmative compliance program defense that, when read together with the diligence duties under the Spanish Companies Act, obligates companies to implement corporate compliance programs designed to prevent criminal activity. In a guest article, Rafael Jiménez-Gusi and Diego Pol Longo, partner and associate at Baker & McKenzie Barcelona, analyze the new law and subsequent developments including guidance issued by the Spanish Public Prosecutor and the Spanish Supreme Court. See “Australia’s Shifting Foreign Bribery Regime” (Dec. 2, 2015).

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