FAQs · The external expert exam
The independent review that obliged entities' anti-money laundering measures must pass every year.
It is the annual, independent review of the internal anti-money laundering controls that article 28 of Ley 10/2010 — Spain's AML/CTF law — requires from obliged entities. It is carried out by an external expert who has previously notified SEPBLAC of their activity, and it is documented in a confidential written report.
The expert does not simply check that a manual exists: they must describe and assess the real effectiveness of the whole system — internal rules, control bodies, customer due diligence, record keeping, detection and reporting of suspicious transactions, and staff training — and propose corrections wherever they find deficiencies. The structure of the report is regulated (Order EHA/2444/2007) and it must be issued no later than two months after the reference date.
The report is not sent to SEPBLAC automatically: it remains at the authority's disposal, to be produced in the event of an inspection. Deficiencies identified must be raised with the entity's governing body within three months at most.
The exam is annual, although after a full report the law allows follow-up reports in the two subsequent years. Not every obliged entity is subject to the exam: see the exemptions.
Legal basis:
Reviewed: August 2026 · PBK Asesores — external experts in AML/CTF before SEPBLAC since 2010, more than 900 exams performed.
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