The new Anti-Corruption Act: clearly defined to cover foreign juristic persons registered abroad

On 22 July 2018, the Act Supplementing the Constitution Relating to the Prevention and Suppression of Corruption came into effect, replacing the previous anti-corruption law from 1999. Among other things, the reason for implementing the new law is to enhance measures and mechanisms to prevent and suppress corruption and willful misconduct.


New obligation for Spanish companies to disclose their ultimate beneficial owners

On 21 March 2018, the Spanish Ministry of Justice issued Ministerial Order 319/2018 which requires Spanish non-listed companies to disclose their ultimate beneficial owners (“UBO“) to the Companies Registry and keep said information updated. The new UBO reporting measure is motivated by Directive 2015/849 of the European Parliament and of the Council on the prevention of the use of financial system for the purposes of money laundering or terrorist financing (the “Fourth Directive“) which imposes an obligation upon the Members States to hold the beneficial ownership information in a central register and make it available with certain restrictions. Paradoxically, Spain has not yet fully implemented the Fourth Directive.