Spanish legal community has pleaded, at least since 2000, for the implementation of a comprehensive Spanish leniency program. The existence of such instrument has been regarded as a condition for a proper coordination between the Commission's activity and that of the Spanish antitrust authorities. It was also seen as a way to improve Spain's relatively poor record in cartel prosecution. The fundamentals of the new leniency system were laid down for the first time by the new Spanish Competition Act itself (Act 15/2007, of 3 July 2007, hereinafter, "the Competition Act" [1]. Article 65 thereof states that the Spanish antitrust authority will exempt an undertaking or a natural person from the payment of a fine that would otherwise have been imposed on them in two different situations:
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The Spanish Government presents a proposal for an implementing regulation of the Spanish leniency program and makes it subject to public consultation
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