General Counsel Scramble After Spain Passes Sweeping New Criminal Code: "Spain will begin enforcing a sweeping new criminal code that holds grave concerns for general counsel of any company that operates or wants to operate in that country. The code for the first time establishes criminal liability for business entities, and it imposes some severe penalties.

Punishment can include 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 said.

Madrid attorney Florentino Orti, who heads the criminal litigation group at the Spanish law firm Garrigues, said in-house lawyers are worried about the new law's possible impact. 'We have received many calls seeking our advice on how to deal with this new regulation,' Orti added, especially as regards corporate compliance."

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