10/03/2026
Our founder, published in Madrid.
Confilegal, Spain's news site for the legal profession, ran a column by Adrian A. Holguin, founder of CannaShark Consulting and principal of Holguin & Company, on Sept. 26. The case: a watch company fined €133,251 for 515 cash payments of exactly €1,000, and a court that annulled the fine because the company's reading of the rule was a reasonable mistake.
It counted as reasonable because every payment was on the books and traceable. That is the same discipline we build for cannabis operators here: write the interpretation down before anyone asks, make every transaction traceable, and do it in the quiet weeks.
Column in Spanish: https://confilegal.com/20260926-interpretacion-normativa-trazabilidad-defensa-sanciones/