Are car dealers and vehicle traders obliged entities?

Yes. Trading professionally in goods — and a vehicle is one — makes the company an obliged entity in respect of the transactions in which €10,000 or more is collected or paid in cash (arts. 2.1.w and 38 of Ley 10/2010), whether in one operation or several that appear linked. And if the business also intermediates in loans or credit for operations other than the sale of its own vehicles, it becomes an obliged entity under the full regime (art. 2.1.k).

The two figures that must not be confused:

• €1,000 is the general cash-payment limit when a business is involved (Ley 7/2012, as amended in 2021). For non-resident private individuals the limit is higher — which is why the significant cash operations in this sector are concentrated today among foreign buyers, a familiar profile in used-vehicle sales and exports.
• €10,000 is the threshold that activates the trader's obliged-entity status on the cash transaction.

The art. 38 regime does not impose every obligation in the law, but it does impose the ones that generate the most enforcement files: formal identification of the customer, special examination of unusual activity, suspicious transaction reports to SEPBLAC, refraining from executing suspicious operations, confidentiality and record keeping.

The typical mistake we find: believing that "since cash can no longer be taken, this does not concern us" — while export deals keep being closed in cash out on the forecourt. For groups and used-vehicle chains, what works is a customer-and-cash acceptance policy applied across the network, plus short training for the sales team: it is the first thing an inspection will ask about.

Legal basis:

• Arts. 2.1.w and 38 of Ley 10/2010
• Art. 2.1.k of Ley 10/2010 (credit intermediation)
• Art. 7 of Ley 7/2012 (cash-payment limit, as amended by Ley 11/2021)

Reviewed: August 2026 · PBK Asesores — external experts in AML/CTF before SEPBLAC since 2010, more than 900 exams performed.

Does this affect you? We will confirm it in a two-minute call → Contact · +34 91 110 28 29

Related:

• Is your company an obliged entity?
• Penalties under Ley 10/2010
• Mandatory AML training
• All frequently asked questions