Foreign Direct Investment Regulation Guide – Global Competition Review

06 December 2022
The Foreign Direct Investment (FDI) control regime in Spain is mainly governed by the Spanish Act on the legal regime of capital movements and economic transactions abroad (the Spanish Act 19/2003) and Royal Decree 664/1999, of 23 April 1999, on foreign investments (RD 664/1999).
Specifically, the consolidated version of Article 7 bis of Act 19/2003 lays out the main principles of the FDI screening mechanism in Spain (the General Screening Mechanism) (as amended by Royal Decree-Law 8/2020, of 17 March 2020, on extraordinary urgent measures to deal with the economic and social impact of covid-19). Subsequently, the General Screening Mechanism has been amended and supplemented by Royal Decree-Law 11/2020, of 31 March 2020, on additional urgent measures in the social and economic field to deal with covid-19; Royal Decree-Law 34/2020, of 17 November 2020, on urgent measures to support business solvency and the energy sector as well as on taxation; Royal Decree-Law 12/2021, of 24 June 2021, which adopts urgent measures in the field of energy taxation and energy generation, and on the management of regulation tax and the water use tariff; and Royal Decree-Law 27/2021, of 23 November, which extends certain economic measures to support recovery.
In addition, the Spanish government will soon adopt a regulation developing the General Screening Mechanism with a view to clarifying, inter alia, the categories of transactions; the thresholds of those transactions for exemption from the General Screening Mechanism; and the definition of strategic sectors. Meanwhile, the Draft Royal Decree on Foreign Investments (the Draft) has been published following the public consultation held last November.[2] Until the final royal decree enters into force, the Draft is proving to be very useful for lawyers assessing FDI as, among other points, it defines in greater detail the strategic sectors, clarifies which investors would be subject to notification regardless of the nature of the target’s activities, and explains what substantive criteria are taken into account in the assessment to decide whether or not to authorise the investment.
The Ministry for Industry, Trade and Tourism (in particular the Sub-Directorate General for Foreign Investments) is the body in charge of reviewing filings under the General Screening Mechanism and proposing the decisions to the Council of Ministers, which ultimately decides on transactions.
Notwithstanding the foregoing, filings under the simplified procedure shall be notified to, and authorised by, the Directorate General for International Trade and Investment.[3]
Finally, in the case of foreign investments affecting the national defence sector, the Ministry of Defence is in charge of reviewing filings and making proposals to the Council of Ministers, which ultimately decides on transactions (the Defence Screening Mechanism).
The Spanish FDI screening regime applies to two main areas:
The General Screening Mechanism applies to FDIs conducted by foreign investors from a list of strategic sectors in which activities may have implications for national security, public order and public health, provided that one of the following two criteria are met:
The aforementioned strategic sectors are the following:
As mentioned above, one of the novelties of the Draft is the attempt to clarify what specific strategic sectors or areas of investment are affected by the General Screening Mechanism. To this end, it contains an extensive article in which it clarifies that, for example, ‘technologies developed under programmes and projects of particular interest to Spain’ are those that benefit from a significant amount or percentage of funding from the national or EU public budget.
In relation to the term ‘foreign investor’, there are three definitions:
Last, the General Screening Mechanism also covers certain investments because of the subjective characteristics of the foreign investor, regardless of the sector affected. These characteristics relate to foreign investors that:
Nevertheless, the Defence Screening Mechanism is specifically established in Article 11 of RD 664/1999 for foreign investments made in Spain in activities directly concerning national defence, such as the production or trading of, or other activities concerning, weapons, munitions, explosives and war materials.
Regarding the objective scope, the concept of activities ‘directly related to national defence’ under the Defence Screening Mechanism must also cover the production or trading of, or other activities concerning, those products included in Annex I of the Spanish Regulation on the control of foreign trade in defence material, other materials and dual-use products and technology, approved by Royal Decree 679/2014.[6]
In the case of companies listed in Spain that carry out these activities, authorisation will be required only for acquisitions by non-residents of more than 5 per cent of the share capital of a Spanish company, or those that, without reaching the threshold, allow the investor to form part, directly or indirectly, of a company’s management body (in accordance with the provisions of Royal Decree 377/1991, of 15 March 1991, on the notification of significant share­holdings in listed companies and of acquisitions by these of their own shares).
The Spanish FDI control regime covers the acquisition of Spanish target companies as well as, according to the current interpretation by the administration, Spanish subsidiaries and assets.
However, there is no guidance for the time being on, for example, the possibility to close a deal globally prior to local clearance.
As indicated in the recitals of the aforementioned regulations, the situation caused by the covid-19 pandemic and the subsequent economic and social crisis left Spanish companies in a situation of unprecedented vulnerability.
This was the trigger for the initial adoption of these regulations, which the subsequent economic recovery and the ongoing consequences of the war in Ukraine (both economic and hybrid threat-related) have increased the interest in consolidating this mechanism of closer control (i.e., the General Screening Mechanism). In fact, the Draft itself – which would confirm the transition from a mostly liberalised system to one with increased review – indicates that the substantive criterion to be considered is the risk that such investments could affect public security, public health, public order, national defence or foreign action.
Besides the urgency caused by the pandemic and subsequent international events, the need for this change of system, and for coordination at EU level in relation to the screening of foreign investments, had been suggested for years. As a result, the EU FDI Screening Regulation was approved and became fully effective as of 11 October 2020.[7]
In doing so, the aim of both interdependent systems is to defend the European Union and Spain’s open strategic autonomy and to ensure that strategic capabilities are not conditioned or diminished while remaining open to foreign investment.
When the relevant thresholds are met, notification is mandatory for all FDIs that are carried out in any sector that may concern national security, public order or public health in Spain (and particularly in those strategic sectors listed in Article 7 bis of Act 19/2003), or made by the ‘under-all-cases’ foreign investors (as defined in the previous section) regardless of the business of the company in which it invests.
It is important to stress that the transaction cannot be implemented until it is cleared by the Council of Ministers.
Nonetheless, voluntary pre-filings and consultations before the Sub-Directorate General of Foreign Investments of the Ministry for Industry, Trade and Tourism are common if there are reasonable doubts as to whether the relevant transaction may be subject to FDI screening.
In fact, according to the recent publication by the Ministry for Industry, Trade and Tourism of the aggregate data on FDIs under the General Screening Mechanism in Spain, the Sub-Directorate General for Foreign Investments received 334 consultations in 2020 and 231 in 2021.[8]
Besides that, another novelty of the Draft is that it establishes that voluntary pre-filings/consultations shall be resolved in 30 business days and that the lack of a formal decision within that period implies that the transaction is subject to the Screening Mechanism and, therefore, requires authorisation prior to execution.
In relation to the Defence Screening Mechanism, notification is mandatory for all foreign investments in Spain regarding activities that directly relate to national defence, such as the production or trading of weapons, munitions, explosives and war materials.
As under the General Screening Mechanism, the transaction cannot be completed until clearance is given by the Council of Ministers.
Therefore, for both the General and the Defence Screening Mechanisms, the foreign investor must request prior administrative authorisation for any transaction that falls under its scope of review. There is no applicable deadline for filing a notifiable transaction, although it should always be done before completion.
There is no timetable scheduled for the process of reviewing a notifiable transaction except that the Council of Ministers shall issue a formal decision within six months of the notification to the Ministry for Industry, Trade and Tourism (time starts running once the notification is formally lodged). The lack of an express decision shall be deemed to have a negative effect (referred to as negative administrative silence). This period is reduced in the Draft to three months and the negative effects of the lack of a formal decision on the notification for authorisation are maintained.
Having said that, it is the responsibility of the direct acquirer to file a transaction that is notifiable under the General or Defence Screening Mechanism before the relevant authority.
With regard to the General Screening Mechanism, there is a specific form for filing available on the website of the Ministry for Industry, Trade and Tourism.
It may be expected that the content of the filing will be expressly included and specified in the Royal Decree with the developing regulation of the General Screening Mechanism to be adopted soon (discussed in more detail below).
As for the Defence Screening Mechanism, the Ministry of Defence provides on its website a guide on how to request an authorisation that specifies the information and documentation that the foreign investor should provide when notifying a transaction.
No filing fees apply in either case.
Ultimately, these proceedings are confidential, subject to the general rules governing Spanish administrative proceedings.
Failure to notify or suspend the completion of a transaction caught by the regime would represent a very serious infringement of Act 19/2003.
FDI carried out without prior authorisation is void and without legal effect until it is duly validated by obtaining the corresponding authorisation from the Council of Ministers.
In addition, a fine may be imposed, the amount of which may be up to the total value of the transaction, but certainly not less than €30,000, and a public or private warning can be imposed.
The FDI control scheme focuses on the effects of acquisitions on national security, public order and public health in Spain.
The substantive grounds for review have not yet been developed by the current legislation. Nevertheless, the Draft details the grounds for review and explains that the substantive criterion to be considered is the risk that such investments could affect public security, public health, public order, national defence or external action. Furthermore, there is no discretion to review transactions that do not meet any of the relevant thresholds.
The Council of Ministers is the competent authority to clear (including with conditions) or block FDIs in Spain that are subject to the General and the Defence Screening Mechanisms. However, filings under the simplified procedure are decided by the Directorate General for International Trade and Investment.
The possibility of appeal is not specified in the current legal framework. However, according to Spanish Act 29/1998, of 13 July 1998, on the contentious-administrative jurisdiction, the Contentious-Administrative Chamber of the Spanish Supreme Court is the competent body to hear appeals against the decisions of the Council of Ministers.
The current FDI regime in Spain does not regulate the involvement of third parties in the General Screening Mechanism.
Notwithstanding this, under the general public law regime, third parties have the right to submit writs or observations before the administration at any time. In our opinion, this right would also apply to filings under the Defence Screening Mechanism. It should also be noted that the Ministry for Industry, Trade and Tourism and the Ministry of Defence (the competent body for handling FDI filings under the General Screening Mechanism) could coordinate with other bodies and request their views on certain investments. This would largely depend on whether an investment could affect regulated sectors falling within the scope of other ministries (such as energy or health).
Finally, since the full application of the EU FDI Screening Regulation on 11 October 2020, the European Commission and other EU Member States can be involved in the review of FDI filings in Spain (they can provide comments or an opinion no later than 15 calendar days following receipt of the notification, and request additional information).
The Council of Ministers can give conditional clearance of FDIs in Spain. This possibility was introduced by Article 6 of Act 19/2003, in which it is indicated that operations within the scope of suspension of the liberalisation regime can be carried out with prior administrative authorisation and under the conditions established as part of that authorisation. This is a legislative precedent in which conditional clearance is included.
Furthermore, a breach of any such conditions will be considered a very serious infringement (under the fourth final provision of RD 8/2020).
Finally, the Draft of the Royal Decree on Foreign Investment (which is currently being processed and will replace RD 664/1999) also confirms (in Article 18) this possibility of applying conditions or measures for mitigating risk.
The Council of Ministers publishes on its official website press releases with brief references to its final decisions on FDI. In addition, Article 14 of Spanish Act 19/2013, of 9 December 2013, on transparency, access to public information and good governance establishes several limits on the right of access to the information held by the administration on the basis of confidentiality or the protection of economic or commercial interests. In fact, the Draft reserves its Article 25 to the processing of personal data and the confidentiality of the information transmitted.
On the other hand, a noteworthy recent development is the publication by the Ministry for Industry, Trade and Tourism of the aggregate data on FDIs under the General Screening Mechanism in 2020 and 2021.
According to this information, in 2020 a total of 28 transactions (15 of them through the simplified proceedings) were reviewed under the scope of the General Screening Mechanism. All of them were approved (although one was subject to conditions).
Furthermore, in 2021, 48 transactions were submitted for prior authorisation of which only three were analysed through the simplified procedure. All transactions were finally authorised, six of them subject to conditions – also called risk mitigation measures.[9]
A good example of clearance subject to conditions is the Decision of 4 August 2021 regarding the investment of the Australian fund IFM in the Spanish company Naturgy. According to the press release issued by the Spanish government,[10] up to nine conditions were imposed on the investor, including (1) to support the investment of the company in projects relating to energy transition in Spain; (2) to support the maintenance of the effective management and headquarters in Spain; (3) to support the maintenance of a significant part of the group in Spain; and (4) not to support any divestment proposal that would involve the loss of control of subsidiaries that could put at risk the proper functioning of gas and energy transportation in Spain.
The covid-19 pandemic and its economic consequences on Spanish companies have been important factors in the regulation of FDI in Spain.
This situation has left some Spanish companies in a situation of unprecedented vulnerability, causing their value to decline rapidly, which has shown to the legislator the need to protect the strategic sectors of Spain’s economy and to safeguard national security and public order. This has entailed the adoption of the General Screening Mechanism in Spain.[11]
To this end, Royal Decree-Law 8/2020, of 17 March 2020, on extraordinary urgent measures to deal with the economic and social impact of covid-19, introduced Article 7 bis suspending the liberalisation regime.[12] In this way, the ex ante authorisation mechanism was introduced.
The persistence of the health and economic crisis over time has resulted in new transitional measures and extensions such as, in particular, a temporary framework (originally in force until 30 June 2021 then extended to 31 December 2021 and now, once again, extended to 31 December 2022) by which the Spanish FDI screening mechanism shall also cover investments in strategic sectors made by investors within the EU and EFTA, either (1) in publicly listed companies in Spanish stock exchanges or (2) where the value of the investment is above €500 million.
Finally, the receipt of European funds for the economic recovery after the pandemic (NextGenerationEU) has maintained and boosted the need to protect those companies that have benefited from them – as we have seen above when explaining the strategic sectors.
One of the most relevant changes has been the paradigm shift from liberalisation to precaution and screening. Within the latter, the changes have been notable; for example, from controlling only those investments concerning national security and defence[13] to contemplating other sectors that in practice have also proven to be sensitive and strategic. The regime has been extended, therefore, to cover certain infrastructures, both physical and virtual (transport, health communica­tions, electoral or financial, etc.), critical dual-use technologies (artificial intel­ligence, nanotechnologies, biotechnologies, etc.), supply key inputs (energy, food security, etc.) and sectors with access to sensitive information (in particular to personal data, or with capacity to control such information) and the media.
With regard to the review timetable, it should be stressed that the Council of Ministers currently has a deadline of six months (reduced to three months in the Draft) to decide whether or not to authorise a transaction. This timing must be considered as part of the strategy of the transaction, especially given that completion of the overall investment operation can only occur once all the mandatory authorisations have been obtained. For this reason, any extension to the duration of the procedure must be avoided.
Furthermore, if the Draft is finally approved, it will need to be considered that it establishes that the authorised investments must be carried out within the period specifically indicated in the authorisation or, failing that, within six months. If the period elapses without the investment having been made, the authorisation will expire, unless an express extension is obtained.
Finally, with regard to the sanctions for gun-jumping of the Screening Mechanism, these include invalidity, until investments are validated by obtaining a retrospective authorisation, and financial penalties.
Many of the changes introduced will remain in place permanently whereas others seem to have been introduced only temporarily to cope with the exceptional situation resulting from the covid-19 crisis.
As regards permanent changes, the main one is the General Screening Mechanism itself. At EU level, the coordination system and the mechanism for the exchange of information between Member States under the EU’s FDI Screening Regulation will also be permanent as per other areas covered by the Regulation.
As regards the changes that are likely to be temporary, the most relevant is the extension of the General Screening Mechanism to certain transactions carried out by investors from the European Union and EFTA until 31 December 2022.
However, while the Draft has already given some indications, the future regulatory development, once finally approved, will show more clearly the scope of these changes and whether they will be permanent.
Enforcement practice in Spain is, for the time being, characterised by the lack of a comprehensive FDI regime and by the subsequent uncertainty. The provisions of the General Screening Mechanism are generally construed broadly and on a teleological and case-by-case basis. For this reason, a higher number of voluntary pre-filings and consultations are being submitted to the Sub-Directorate General of Foreign Investments than FDI authorisations requests per se.
Moreover, given the confidentiality of the proceedings and the limits on the rights of access to public information, there is not much information or detail available about FDI reviews and authorisations other than brief press releases.
Notwithstanding the above, the first statistics of the enforcement practice for 2020 and 2021 represent a positive development that provide an insight into the development of FDI practice in Spain.
We have for instance learned that a total of 28 transactions (15 of them through the simplified proceedings) were reviewed under the scope of the General Screening Mechanism in 2020. All were approved (one subject to conditions). In 2021, 48 transactions were submitted for authorisation (three being analysed through the simplified procedure). All of them were authorised (six subject to conditions – also called risk mitigation measures[14]).
The authorisation procedure is set out in Article 11 of the Spanish Order of 28 May 2001, which establishes the proceedings applicable to foreign investment declarations.
The form for FDI filing[15] must be submitted to the Sub-Directorate General for Foreign Investments of the Directorate General for International Trade and Investment. It must be drafted and completed in a new document covering all the points listed in the table of contents, which is structured around four main points:
There is a total of 36 questions that need to be answered. In addition, it should be borne in mind that during the handling of its investigation, the Directorate General for International Trade and Investment may ask for any data, reports or information it deems appropriate.
Apart from that, for the purposes of the cooperation mechanism established by the EU FDI Screening Regulation, the second part of the form includes a request for information from the investor for the purposes of notifications pursuant to Article 6 of the Regulation.
This template was developed by the European Commission at the initiative of the Directorate General for International Trade and Investment to improve the cooperation mechanism. In this way, minimum information requirements were brought together and standardised to facilitate examination by the other 26 Member States and the European Commission (in case an FDI may affect the security or public order of at least one other Member State) without delaying the investigation carried out in the notifying Member State.
The form is detailed and exhaustive, requiring the provision of a large amount of technical information on all the elements involved in and potentially affected by the operation. It is advisable to provide detailed and accurate information as this may ease the subsequent handling of the investigation and obtaining clearance. As the European Commission highlights, this will also be relevant to avoid authorities in the other Member States and the European Commission requesting additional information, reserving the right to comment or issuing opinions.
Providing wrong or inaccurate information in response to information requests during the authorisation proceedings will be considered a very serious infringement according to Article 7 bis of Act 19/2003, which introduces the General Screening Mechanism in Spain.
First, it should be noted that the six-month term for the Council of Ministers to reach a decision is the legal maximum, but in practice it takes less time (and this will probably be the case in the future, since, as explained before, the Draft reduces it to three months). It is nevertheless always advisable to establish the current workload of the competent authority to have a better idea about when to expect a decision. The timing would also depend on the complexity of the investment and the sectors affected as well as the potential intervention of other government bodies in the process.
Second, with respect to the interplay with merger control, it is important to clarify that both proceedings are different and fully independent, each with its own governing regulations and procedures, thresholds, timelines and competent authority (merger control filings are handled by the Spanish Competition Authority and governed by the Spanish Competition Act).
Notwithstanding the above, it should be noted that on the FDI notification form, the authorities also ask if the investment is subject to another assessment, authorisation or monitoring in the Member State undertaking the screening, in another Member State or in a third country (including merger control).
In any event, both regimes must be borne in mind for the purposes of the jurisdictional assessment and in terms of transaction planning. In particular, it has been clarified[16] that the concept of ‘control’ under the General Screening Mechanism is aligned with the Spanish Competition Law. This represents a positive development insofar as it provides greater legal certainty for companies intending to make investments in Spain. Since the interpretation of the legal concept of ‘control’ can sometimes be quite complex under Spanish competition law provisions, it is expected that the National Markets and Competition Commission’s precedents will be important in resolving possible doubts about the enforcement of the Screening Mechanism.
Spanish competition law interprets the concept of ‘control’ in a broad manner. According to Article 7.2 of the Spanish Competition Act, ‘control shall result from the contracts, rights or any other means which, considering the factual and legal circumstances, confer the possibility of exercising decisive influ­ence over an undertaking’. This means that control can be acquired either by a single company (sole control) or by several companies in relation to joint ventures (joint control). Control can in turn be positive (e.g., the possibility of adopting unilateral decisions about the strategic behaviour of the target company) or negative (usually through the ability to block, or exercise veto rights on, strategic decisions).
If each set of thresholds is met, the respective FDI and merger control authorisations must be requested prior to carrying out the transaction. Otherwise, the investors will be sanctioned for gun-jumping the corresponding regimes.
The Spanish government still plans to approve a royal decree developing the regulation of the General Screening Mechanism with a view to clarifying, inter alia, the categories of transactions and the thresholds of transactions that will be exempted from the General Screening Mechanism, the definitive content of the filing, the participation of third parties, the extraterritorial application, or the permanent or transitory nature of certain provisions (e.g., the scope of the simplified proceedings or FDIs made by investors from the European Union or EFTA).
For the time being, the publication of the Draft and of the first statistics of the enforcement practice for 2020 and 2021 represent positive steps towards the practical consolidation of the FDI Screening Mechanism in Spain and its long-term application beyond the covid-19 health crisis and economic recovery for which it was initially adopted.
However, until we have a solid legal framework with the entry into force of the final royal decree, the FDI control in Spain will still be subject to some uncertainty – as proven by the submission of 334 consultations before the Sub-Directorate General of Foreign Investments of the Ministry for Industry, Trade and Tourism in 2020 and 231 more in 2021, according to data published by the Ministry itself.
The Minister for Industry, Trade and Tourism is also empowered to issue the necessary regulations for the correct implementation and application of the implementing provisions issued by the government in relation to the above.
1 Casto González-Paramo Rodríguez is a partner, Alfredo Gómez Álvarez is a senior associate and Raquel Fernández Menéndez is an associate at Hogan Lovells International, LLP.
2 The complete text of the Draft is available at: https://comercio.gob.es/es-es/participacion-publica/Paginas/DetalleParticipacionPublica.aspx?k=465.
3 There is a simplified procedure for those foreign direct investments agreed between the parties (or the subject of a binding offer in which the price has been agreed) prior to the entry into force of Royal Decree-Law 8/2020, of 17 March 2020, on extraordinary urgent measures to deal with the economic and social effects of covid-19 (on 19 March 2020), and whose amount is equal to or greater than €1 million and less than €5 million (until the entry into force of regulatory developments of the General Screening Mechanism).
4 Thus, according to Article 7.2 of the Spanish Competition Act, ‘control shall result from the contracts, rights or any other means which, taking into account the factual and legal circumstances, confer the possibility of exercising decisive influence on a company, and in particular by means of: (a) ownership or use rights of all or part of a company’s assets; (b) contracts, rights or any other means that allow a decisive influence on the composition, deliberations or decisions of the bodies of the company’.
5 By way of illustration, an acquisition of control from a competition law perspective could take place, in respect of a company whose shares have been pledged, on the basis of loan agreements that confer strategic veto rights to the lenders (even if they are not present in the shareholding). It should be noted that such atypical transactions could occur more often in times of economic crisis and for companies in an insolvency situation. Furthermore, the concept of control under Article 7.2 of the Spanish Competition Act may arise not only from the acquisition of shares or shareholders’ agreements, but also by other contractual means relating to intangible assets with access to the market (such as industrial property rights, know-how or goodwill), which could raise serious doubts as to whether they are also covered by the General Screening Mechanism.
6 Section 1 of this Annex I replicates the European Common Military List, and Section 2 lists dual-use items which, in turn, are also included in Annex I and IV of the Dual-use Regulation (see the Common Military List of the European Union (2019/C 95/01) adopted by the Council on 18 February 2019 and Council Regulation (EC) No. 428/2009 of 5 May 2009 setting up a Community regime for the control of exports, transfer, brokering and transit of dual-use items).
7 Regulation (EU) 2019/452 of the European Parliament and of the Council of 19 March 2019 establishing a framework for the screening of foreign direct investments into the Union (the FDI Screening Regulation). Additionally, on 26 March, the Commission Communication with guidelines for Member States on foreign direct investments and the free movement of capital from third countries as well as the protection of Europe’s strategic assets, was adopted prior to the application of the FDI Screening Regulation.
8 More detailed information is available at https://comercio.gob.es/InversionesExteriores/Paginas/control-inversiones.aspx.
9 Available at https://comercio.gob.es/InversionesExteriores/Paginas/control-inversiones.aspx.
10 Available at www.lamoncloa.gob.es/consejodeministros/Paginas/enlaces/030821-enlace-naturgy.aspx.
11 Under Spanish Act 19/2003, Article 7 bis.
12 This possibility is included in Spanish Act 19/2003, Article 7.
13 Royal Decree 664/1999, Article 11.
14 Available at https://comercio.gob.es/InversionesExteriores/Paginas/control-inversiones.aspx.
15 Available at https://comercio.gob.es/InversionesExteriores/Paginas/control-inversiones.aspx.
16 By means of Royal Decree-Law 34/2020, of 17 November 2020, on urgent measures to support business solvency and the energy sector as well as on taxation.
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