Spain

Global sanctions guide

South Korea
Sudan
  1. Does Spain have a sanctions regime in place?

Yes.

  1. Does Spain implement UN sanctions?

Yes. Spain is a member of the European Union, which implements UN sanctions in all member states by way of directly applicable regulations.

  1. Does Spain implement an autonomous sanctions regime?

No.

  1. What is the nature of the sanctions regime in Spain?

Spain follows the restrictive measures laid down by the UN, the EU and other international organisations which are binding on Spain. The Spanish sanctions regime is regulated under the Money Laundering and Counter Terrorism Act 10/2010 (“the Act”). To the extent that UN regulations are not implemented by way of directly effective EU regulations, once published in the official journal (BOE2) they automatically become part of Spanish law (Article 96(1) of the Spanish Constitution).

  1. Does Spain maintain a list of sanctioned individuals and entities?

No. Spain relies on UN and EU sanctions lists, pursuant to the Act.

  1. Are there any other lists related to sanctions in Spain?

No.

  1. Does Spain have a licensing or authorisation system in place?

No.

  1. What are the consequences for a breach of sanctions in Spain?

The infringement of any EU restrictive measure is categorised as the most serious infringement and gives rise to sanctions under the Act.

In addition to a public warning addressed to the infringer, the Administration can impose fines between €150,000 and any of the following amounts: (i) 5% of the net assets of the company or person being sanctioned, (ii) double the amount of the economic value of the given operation, or (iii) €1,500,000. Furthermore, the infringement can lead to the removal of any administrative authorisation granted to operate in the market.

Penalties imposed directly on individuals are also available, such as fines between €60,000 and €600,000, or the prohibition to exercise any management task in the sanctioned company or in any other company prescribed by the law for a maximum of 10 years.

  1. Where are the relevant regulators in Spain and what are their contact details?

The relevant regulator is La Comisión de Prevención del Blanqueo de Capitales e Infracciones Monetarias, (the Prevention of Money Laundering and Monetary Infringements Commission, or “SEPBLAC”).

Calle de Alcalá 48
28014 Madrid
Spain

T: (+34) 913 38 88 08

Contributor law firm

Crisanto Pérez-Abad, Eversheds Nicea, Paseo de la Castellana, 66, 28046, Madrid