Enrique Aznar

Ethical governance for complex decisions.

I advise organisations under regulatory, technological and reputational pressure — when compliance is not the problem, but deciding what compliance means.

I work with organisations facing
Now Professor · IE University · Academic Director · IE-Elecnor Knowledge Hub on Ethical Business
Enrique Aznar
— Madrid · 2026
§ 01 — THE WORK

Three planes of intervention, one decision layer.

01
Strategic governance

Governance and Boards

Decision structure, board, oversight and accountability in complex regulatory environments. I design the layer where the difficult decisions are made — and my work ends when the board no longer needs me to make them again.

Typical mandates board structuring risk committees independence succession oversight
02
Operational integrity

Compliance, Culture and Ethical Systems

There is no effective compliance programme without a corporate culture to sustain it.

Compliance models, internal investigations, organisational culture and ESG frameworks that are operational — not aspirational. Institutional legitimacy begins in the board's decision matrix, not in the reports.

Typical mandates compliance programmes internal investigations code of conduct due diligence operational ESG culture transformation
03
Frontier technology

Artificial Intelligence and Digital Assets

AI Act applicability and role classification, Article 50 transparency, readiness for high-risk systems and board-level AI governance. Tokenisation, legal structuring of DAOs and navigating regulatory sandboxes. Where the AI Act, MiCA and the DLT Pilot are still being written — and where every decision taken today shapes tomorrow's regulatory framework.

Typical mandates AI Act AI governance generative AI policies ISO/IEC 42001 MiCA DLT Pilot tokenisation DAO structuring sandbox
Capabilities
Governance
board structuring committees independence oversight decision matrix accountability succession
Compliance and Ethics
compliance programmes internal investigations code of conduct due diligence culture transformation operational ESG institutional legitimacy
AI and Digital Assets
AI Act AI governance article 50 high risk ISO/IEC 42001 MiCA CASP DLT Pilot tokenisation DAO structuring sandbox legaltech
§ 02 — CASES

Three decades at the frontier of governance crises, regulatory innovation and organisational transformation.

A selection of representative mandates. Client-identifying details have been modified.
01
Telecommunications · EMEA

Corruption crisis at a NASDAQ multinational

DOJ investigation · 10+ jurisdictions · Management Board
Global programme restructured
+
Situation
A $13.5bn telecoms group facing a serious bribery and corruption crisis across multiple jurisdictions under DOJ investigation.
Work delivered
Management Board member and Chief Compliance Officer. Design and implementation of the post-crisis compliance architecture, managing the tension between US enforcement and European operational realities. Participation in the selection process for the independent monitor required under the DOJ resolution.
Outcome
Global compliance programme restructured across 10+ jurisdictions, laying the groundwork for the subsequent work with the independent monitor — completed after my departure from the organisation.
02
Fintech · Spain · CNMV

First debt tokenisation in the CNMV Sandbox

RWA tokenisation · DLT Pilot · First cohort
First cohort approval
+
Situation
Regulatory gap in Spain for real world asset tokenisation. Need for a legal structure under the DLT Pilot Regime and Spanish securities law.
Work delivered
Co-founder and lead on legal and regulatory design. Full legal structure, investor documentation and framework for regulatory interaction with the CNMV.
Outcome
First cohort approval in the CNMV Fintech Sandbox. Regulatory precedent in Spain.
03
Technology · Global operations

Culture transformation in a crisis-hit technology group

Distributed governance · 3 regions · Corporate values
3 regions · Board reporting
+
Situation
Large technology company operating in volatile markets with conventional control models that did not reflect organisational reality.
Work delivered
Values-based culture transformation programme. Replacement of conventional hierarchies with distributed governance models. Redesign of how the organisation decided, allocated accountability and measured integrity.
Outcome
Adopted across three operating regions. Embedded in board reporting and performance metrics.
04
Digital Marketing · Compliance · Spain

When a digital startup grows without controls: lessons from the affiliate sector

Affiliate ecosystem · Value chain · Reputational risk · ESG
Reference case
+
The pattern
Fast-growing digital marketing and affiliate companies operating without governance structures, without control over their affiliate ecosystem, and without measuring their impact. The most visible case in Spain (Operation Rikati, 2017) showed how the absence of controls in an affiliate model can escalate into a criminal crisis affecting millions.
Practical application
I use this pattern in executive education (IE Law School) and in advisory work with digital-sector companies. I design ESG governance frameworks, affiliate value-chain due diligence, digital carbon footprint measurement and CSRD/CS3D readiness — tailored to each company's specific business model.
Why it matters today
With Royal Decree 214/2025, the CSRD and the CS3D, digital companies can no longer operate without sustainability structures and controls over their ecosystem.
05
Pharmaceuticals · Sustainability · Italy

Sustainability strategic plan for a European generics leader

€200M+ revenue · 200+ employees · 13 therapeutic areas · Private equity
Plan approved by the Board
+
Situation
Leading generic pharmaceutical company in a key European market, with over €200M in revenue, 200+ employees and presence across 13 therapeutic areas. Asset-light model with a distributed sales network. Owned by an international private equity fund. No formal sustainability strategy or ESG reporting.
Work delivered
Design of the full sustainability strategic plan: materiality assessment, definition of ESG pillars, sustainability governance, KPIs and roadmap. Integration of the pharmaceutical supply chain into the impact analysis. Presentation to and approval by the board of directors.
Outcome
First sustainability strategic plan approved by the Board. Reporting framework aligned with European standards. Positioned as an ESG benchmark in the generics sector.
06
Higher Education · Culture Transformation · Central America

Cultural transformation and ethical governance at a leading university

6,000+ students · Ethos definition · Governance structure · Compliance
Ethos & governance deployed
+
Situation
Leading private university in Central America, with over 6,000 students and internationally accredited programmes. The institution needed to formalise its ethical framework, define its ethos and build a governance and compliance structure adapted to an academic environment — where standard corporate control culture does not fit.
Work delivered
Participatory definition of the institutional ethos with governing bodies, faculty and the university community. Design of the ethical governance structure: ethics committee, whistleblowing channels, academic integrity policies. Training programme for academic leaders.
Outcome
Institutional ethical framework approved by the Board of Directors. Operational ethical governance structure. Compliance programme built from the institution's own identity, not imported from the corporate world.
07
Professional Association · Compliance · Spain

Compliance programme for a leading professional association

Regulated sector · Full programme design · Board-level training
Programme implemented and operational
+
Situation
Professional association with thousands of members, specific regulatory obligations and growing exposure to corporate criminal risks following the Spanish Criminal Code reform. The institution lacked a structured compliance programme and needed one that respected the collegiate nature of its governance.
Work delivered
Assessment of criminal and regulatory risks specific to the professional association sector. Design and implementation of the full programme: code of ethics, risk map, whistleblowing channel, decision protocols and disciplinary system. Training programme for the Governing Board.
Outcome
Compliance programme approved and implemented. Compliance body established. Replicable model for other professional associations in the sector.
§ 03 — IDEAS

Structured thinking on ethical governance.

Articles & chapters

Editorial publications

03
In the media

Press and interviews

10
Videos & podcast

Talks, interviews and podcasts

13
TalksSelected international conferences
  • OECD & Brazilian Comptroller-General (CGU) — "Corruption and Business: What Price do Companies Pay?" Latin-America Conference on Corporate Responsibility. São Paulo.2010
  • International Bar Association — Anti-Corruption Conference. Prague.2009
  • International Bar Association — "Doing the Right Thing". 10th Annual Group Members' Leadership Summit. London.2014
  • IBA & OECD & UNODC — "Anti-Corruption Strategy for the Legal Profession". Madrid & Barcelona.2013
  • UNICEF, Save the Children & UN Global Compact — World Child & Youth Forum. Royal Palace, Stockholm. Panellist on Children's Rights and Business Principles.2013
  • Università Bocconi — "Ethics, Compliance and Corporate Responsibility in the Corporate World". Milan.2010
  • ACC Europe — 20th Annual Conference. "Legal and Compliance: Two Worlds or Only Two Faces of the Same Coin?" Barcelona.2013
  • The Global Compliance Officers' Forum — "Building a Stronger Ethical Culture". Luncheon Keynote. Frankfurt.2016
  • Financial Times — Anti-Corruption Conference. "Whistleblower Hotlines". Düsseldorf.2009
  • IAE–IESE Business School — "Compliance for Senior Management: What Really Matters". Buenos Aires.2013–15
§ 04 — ABOUT

Lawyer · Governance Advisor · Professor · Speaker.

Nearly three decades in senior executive positions at technology and telecoms multinationals — from Arthur Andersen and Price Waterhouse to Freshfields, Dell, Tyco International, Nokia Siemens Networks, Millicom and the Management Board of VimpelCom/VEON (NASDAQ, $13.5bn), until 2017.

Lawyer qualified in Spain and England & Wales. Professor at IE Law School and IE Business School. Academic Director of the IE-Elecnor Knowledge Hub on Ethical Business. Advanced training at Oxford Saïd, IESE, IE and Stanford. Certified in Generative AI for Business Professionals (IE University, 2024).

Co-founder of RealFund, the first Spanish real world asset tokenisation platform approved in the CNMV Fintech Sandbox. Co-Chair of the UK & European Digital Asset Task Force of the Digital Asset Regulatory Authority (DARA) and Regional Director for Europe of the Government Blockchain Association. Active adviser on tokenisation and AI projects in Spain, Europe and the Middle East. Partner and adviser at Voombu, a modular ESG platform for ESRS reporting, risk management and sustainable finance. The legal and compliance practice operates through Aznar Legal & Compliance.

Current positions
  • ProfessorIE University
  • Academic DirectorIE-Elecnor Knowledge Hub
  • Co-founderRealFund
  • Founding PartnerAznar Legal & Compliance
  • Co-Chair, UK & European Task ForceDARA
  • Regional Director · EuropeGovernment Blockchain Association
  • Partner & adviserVoombu
Career · selection
  • Management BoardVimpelCom/VEON (NASDAQ)
  • CCOMillicom · NSN · Tyco
  • CounselDell
  • AssociateFreshfields · PW · Arthur Andersen
Credentials
  • Qualified lawyerSpain (Madrid-Barcelona) · England & Wales
  • Advanced trainingIESE · IE · Oxford Saïd · Stanford
§ 05 — Let's talk

If your board has a decision waiting for structure, that is where we start.

30 minutes, no commitment. You bring the concrete problem; I tell you whether it is something I can help with — and if not, whom you should call.

Start a conversation →
Law firmaznar.legal
MadridAvailable for remote and in-person mandates