Spain is one of the most active jurisdictions in cartel enforcement in Europe. The concurrent efforts of the Spanish National Competition Authority (CNMC) and certain regional competition authorities, a functioning and, broadly speaking, predictable leniency programme, fines on individuals, the possibility of cartel decisions including a prohibition on entering into public-sector contracts, recent amendments of Spanish competition law introduced by the ECN+ Directive, the appointment of Maria Luisa (Marisa) Tierno Centella as the new director of competition at the CNMC and the mushrooming of follow-on cartel civil litigation, all make it potentially very expensive to cartelise with effects in Spain.
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