Industry Association Raids in Spain

The Spanish Competition Authority (the “CNC”) announced today that it has carried out dawn raids at the premises of SEDIGAS, the national gas industry association, and of AOGLP, the national oil industry association.

The CNC is investigating whether anticompetitive agreements have been entered into in the market for the distribution via pipelines of natural and liquefied gas.

The inspection occurs in the context of disciplinary proceedings opened in October 2010 against SEDIGAS in connection with its having prepared a report that included prices quoted for the transmission of gas to various regions of Spain. Information uncovered during the disciplinary proceedings led to the latest raids.

The Spanish proceedings highlight the potential for industry associations and regulatory bodies themselves to become the target of antitrust enforcement action. Given the role that such associations and bodies play in enabling co-ordinated action and information sharing amongst competitors, we recommend a robust compliance policy, training and regular risk audits.

For more information, please contact John Cassels.