The Spanish system for the prevention of money laundering and terrorist financing (AML/CFT) is undergoing a process of transformation. The approval by the Council of Ministers, on 28 July 2026, at first reading, of the Draft Bill on comprehensive measures… Read more

Ms Ortega worked for more than twenty years, from 1994 to 2017, for a company providing administrative services to entities within the financial sector. On numerous occasions, both verbally and by email, she raised internal complaints alleging that she was… Read more

Commentary on the Judgment of the National High Court (First Section, Contentious-Administrative Chamber) No. 139/2026 dated 18 March 2026.   The National High Court Judgment No. 139/2026, which is the subject of this commentary, stems from the contentious- No. 894/2023,… Read more

Analysis of Judgment No. 1734/2026 of 16 February 2026 handed down by the Provincial Court of Madrid (30th Criminal Division). This commentary analyses the recent Judgment No. 1734/2026 of 16 February 2026 handed down by the Madrid Provincial Court, which… Read more

Supreme Court preserves interim protection for Renfe’s in-house legal communications The scope of confidentiality surrounding communications between a company and its in-house lawyers remains a matter of controversy. May an authority access emails, reports and notes exchanged between a company’s… Read more

Case Note on Judgment No. 5487/2026 of the High Court of Justice of Madrid (Labour Chamber), 16th April 2026   Abstract The judgment rules on the appeal filed by an employee, who contends that his dismissal should not have been classified as unfair, as held by the court of first instance, but rather declared null and… Read more

By Albert Estrada and Clara Tarrés, members of Molins Investigaciones Internas The widespread use of artificial intelligence (AI, hereinafter) in our daily lives and in the workplace is now a reality. The numbers speak for themselves: three years after its… Read more

The National Commission for Markets and Competition (hereinafter, CNMC) is the body responsible for promoting and safeguarding competition in the Spanish business environment in the interests of society as a whole. To this end, in June 2020 it adopted the… Read more

On 31 May 2026, Directive (EU) 2026/1021 of the European Parliament and of the Council of 29 April 2026 on combating corruption (hereinafter, Directive 2026/1021 or the Directive) came into force. This legislation is intended to strengthen the European Union’s… Read more

With regulatory compliance now firmly established in Spain, Law 2/2023 fully implemented and the Independent Whistleblower Protection Authority (AINPI) having commenced operations, by 2025 internal investigations had become an established feature of the legal landscape for medium-sized and large companies… Read more

As has been noted for years in the field of compliance, a significant portion of the legal and reputational risks faced by organizations do not arise solely from their internal structure, but rather from the third parties with whom they… Read more

In recent years, Compliance Systems have taken on a central role in the prevention and detection of corporate crime. This trend is evident not only in Europe but also in jurisdictions such as the United States, where the authorities have… Read more

The implementation of a Compliance System has become a cornerstone of modern corporate governance. The consolidation of these systems within the business environment finds its origin in the reform introduced by Organic Law 1/2015, of 30 March, which incorporated into… Read more

Molins Compliance notes that on February 17, 2026, the Council of Ministers approved the Draft Organic Law on Public Integrity as part of the State Plan to Combat Corruption. To this end, significant regulatory changes are being introduced that apply… Read more

Commentary on STSJ Navarra (Social Chamber) No. 302/2025, of 4 September The Labour Chamber of the High Court of Justice of Navarre has upheld a lower court ruling declaring null and void the disciplinary sanction imposed by a company in… Read more

Judgment of the High Court of Justice of Logroño, Labour Chamber, No. 106/2025, of 28 July, p. González González In this ruling, the High Court of Justice of Logroño upholds the lower court’s decision to dismiss the claim for unfair… Read more

This publication analyses the ruling dated 13 March 2025, handed down by Section 2 of the Provincial Court of Burgos, in which the focus of the debate centres on the communication to the works council of the full content of… Read more

As explained in ComplianceKeys#25, the introduction of criminal liability for legal entities  into our legal system, following the reform of the Criminal Code brought about by Organic Law 5/2010 and consolidated by Organic Law 1/2015, represented a structural change in… Read more

In a regulatory environment undergoing constant transformation, Compliance requires continuous and structured monitoring. Throughout the 2025 financial year, significant regulatory changes, judicial developments, technical guidelines, and the consolidation of emerging risks have taken place, directly impacting compliance systems and the… Read more

Commentary on the Judgment of the European Court of Human Rights of 6 November 2025, Guyvan v. Ukraine In the recent judgment of the European Court of Human Rights (ECHR) of 6 November 2025, the Fifth Section of the Court… Read more

Since the Independent Whistleblower Protection Authority (herein after referred to by its Spanish acronym AIPI) began operating in September 2025, it has received numerous enquiries confirming the existence of significant interpretative doubts regarding the practical application of Law 2/2023 of… Read more

This publication analyses the judgment dated 13 February 2025 handed down by the European Court of Human Rights (hereinafter, ‘ECHR’) in the case of Macharik v. Czech Republic, which upheld a claim for violation of fundamental rights enshrined in the… Read more

As explained in the previous ComplianceKeys#25, the reform of the Criminal Code by Organic Law 5/2010 of June 22 introduced criminal liability for legal entities for the first time. However, it was not until Organic Law 1/2015, with Article 31… Read more

This publication analyzes the judgment dated February 18, 2025, handed down by the European Court of Human Rights (hereinafter, “ECHR”) in the case of Romanchenko and Kharazishvili v. Georgia, which upheld a claim for violation of Article 8 (right to… Read more

In this commentary, we analyze the Judgment issued on January 14, 2025, by the Second Section of the European Court of Human Rights (ECtHR) in the case of N.Ö. v. Turkey (Application no. 24733/15). The national proceedings were initiated following… Read more

Money laundering represents one of the main threats to the integrity of the financial system and the transparency of the economy. Its effects transcend the strictly criminal sphere, generating significant legal, reputational and operational risks. Given the magnitude of this… Read more

In recent years, the concept of Sustainability has evolved and become integrated into different areas of our society. Among these is the business world, where it has increasingly become a priority concern and a fundamental pillar in the development of… Read more

Compliance, although initially associated with the private sector, has undergone increasing integration into the public sector in recent years in response to transparency challenges. Historically, many public administrations have been exposed to recurring episodes of corruption, inefficiency and abuse of… Read more

The Supreme Court acquits a legal entity convicted of fraud and takes the opportunity to change the criteria regarding who bears the burden of proof for breach of supervisory duties. At the same time, it provides an overview of the… Read more

Today’s business environment is characterised by the immediacy of information and increasingly intense competition. News and opinions spread at breakneck speed, creating an environment in which transparency, ethics and corporate responsibility are essential for business survival. In this context, companies… Read more

Experience shows that the true value of an organization not only lies in its results, but also in its commitment to regulatory Compliance, ethics, and organizational culture. Over the past decade, several of the most internationally renowned companies in the… Read more

Compliance could be defined as the set of procedures and best practices adopted by companies and organisations to identify and manage the legal risks inherent in their activities, in order to ensure compliance with current regulations and prevent crimes from… Read more

By Paz Valles Creixell. Partner at MOLINS DEFENSA PENAL. More and more frequently, and with increasing concern, at Molins Defensa Penal we assist people who arrive at our office with a mixture of disbelief and distress. They have been summoned… Read more

Spanish Supreme Court (administrative Chamber) Judgement n.º 704/2025, 4th June, judge rapporteur: Requero Ibáñez. The facts that are the subject of the resolution commented refer to an official of penitentiary institutions who, after giving an interview on the television program… Read more

This publication discusses Supreme Court Labour Chamber Ruling No. 23/2025, handed down on 14 January 2025. This ruling upholds an appeal for the unification of doctrine filed by the company STRADIVARIUS ESPAÑA S.A. against the ruling handed down on 18… Read more

Commentary on Supreme Court Ruling (Criminal Chamber) Section 1, No. 457/2025 of 21 May. By means of Supreme Court Ruling No. 457/2025 of 21 May, the First Section of the Fourth Chamber of the Supreme Court dismissed the appeal and… Read more

One of the decisive factors for the Spanish Supreme Court when tipping the balance in assessing the legality of evidence obtained with a potential violation of fundamental rights lies, perhaps surprisingly, in the subjective position of the agent who carried… Read more

Compliance is dynamism and constant evolution. In a regulatory environment in continuous transformation, it is essential to keep abreast of the most relevant changes and improvements in the field, especially those that directly affect compliance systems and corporate legal risk… Read more

Can Parliament, in the exercise of its investigative function, name the political perpetrators of a tragedy without violating their presumption of innocence or damaging their honor? The case of Manuel Azuaga, former president of AENA, reopens a relevant debate on… Read more

Article 18 of the Workers’ Statute. Commentary on judgment (Social chamber), Secc. 1.ª, n.º 874/2024, of 5 June. This publication comments the judgment (social chamber), Secc. 1.ª, n.º 874/2024, of 5 June, which analyses the validity or nullity of the… Read more