- Tomorrow, April 24, the Spanish Association for Standardization, UNE, will publish the new version of the UNE 19601 Standard on Criminal Compliance Management Systems. Requirements with guidance for use, a benchmark to help organizations prevent criminal offences since its appearance in 2017.
- Its implementation has allowed organizations to benefit from greater legal certainty and gain a competitive and reputational advantage, helping them to have their criminal liability mitigated or even waived by demonstrating due diligence and best practices in crime prevention.
- Among the improvements, the new version of the UNE 19601 Standard aligns the regulation of the roles of the criminal compliance function with modern ISO standards, separates training activities from awareness-raising activities, and streamlines the level of control over financial investments.
Madrid, 23 April 2025 - Tomorrow, April 24, the Spanish Association for Standardization, UNE, will publish the new version of the UNE 19601 Standard on Criminal Compliance Management Systems. Requirements with guidance for use, which has become a benchmark for providing organizations with a management model for preventing the commission of crimes within their structure, aligned with the requirements of the Criminal Code and with the best existing international practices.
Originally published in 2017, it has now been revised to adapt to the evolving needs of organizations, align the new version with other relevant market documents, and enhance its content based on insights gained over eight years of implementation.
In the words of Javier García, Director General of UNE and Vice-President of ISO: "Standardization provides an effective response to the challenges of good governance in society and organizations. The new version of the UNE Standard for Criminal Compliance Management Systems, developed with best practices, will strengthen the culture of compliance in Spain and other countries, providing organizations with greater legal certainty and a competitive and reputational advantage".
The new document introduces adjustments to align its content with other relevant publications that have emerged since its original release, such as the ISO Harmonized Structure for management system standards, as well as compliance and whistleblowing management standards developed since 2017, both nationally and internationally.
It also incorporates changes in the formulation of some of its requirements, with the aim of improving its understanding and usefulness for organizations, taking into account the experience provided by companies, consultants and certification bodies that have worked with the Standard over these eight years.
Improvements
Among the improvements, the new version of the UNE 19601 Standard aligns the regulation of the criminal compliance function’s tasks with modern ISO standards, conceptually separates training activities from awareness-raising activities, and streamlines the level of supervision and control over purely financial investments.
The modifications introduced by the Standard will help maintain it as a valuable tool for managing criminal compliance, as it has been in recent years. Organizations that effectively implement this standardized model may see their criminal liability mitigated or even waived by demonstrating due diligence and best practices in preventing and detecting the commission of crimes within their organization. This Standard is certifiable by an independent third party, ensuring that it is applied effectively.
The body responsible for its revision has been the UNE Committee on Compliance Management Systems and Anti-Corruption Management Systems (CTN-UNE 165 SC3), composed of 25 members representing prominent professionals in compliance, companies, law firms, consulting firms, NGOs, universities, and certification bodies, among others.
The UNE 19601 Standard is aimed at all types of organizations, regardless of their type, size, nature, activity or sector, and can be used in jurisdictions other than Spain and by organizations outside of Spain.
Moreover, it has set a precedent and served as a model for other national compliance standards that have emerged in specific areas, such as the UNE 19602, UNE 19603, and UNE 19604 Standards for tax compliance, competition compliance, and labour compliance, respectively.
The successive organic laws that have introduced amendments to the Criminal Code since the publication of the UNE 19601 Standard have reinforced the need for management and control systems applied to the prevention and detection of criminal conduct. Therefore, the reasons that made its development necessary remain relevant.