Spain has increased the risk for companies operating in that country. On December 23 it began enforcing a sweeping new criminal code that for the first time establishes criminal liability for business entities. It also imposes some severe penalties, including a fine, temporary closure of all or part of the business for up to five years, exclusion from government contracts, and ultimately the dissolution of the company.
So far, general counsel in Spain seem to be approaching the new law with caution, according to Robin Scullin, spokesperson for the Association of Corporate Counsel in Washington, D.C. “We reached out to several folks in our ACC Europe chapter, and while they are monitoring the situation, they have no formal policies to speak of yet,” Scullin says.
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