Can your regular adviser do the exam — or you yourself?

No. The law prohibits entrusting the exam to anyone who has provided you with any other kind of paid services during the three years before the report — or who does so in the three years after (art. 28.2). That rules out self-examination, and also a report signed by your regular tax adviser, your agent or your usual consultant.

The reason is the same as in any audit: whoever designed or manages the system cannot be the one certifying to third parties that it works. A report signed by an incompatible professional is questionable in its entirety — the money spent does not buy the cover that was being sought.

In practice, this forces you to separate roles and to plan ahead:

• If one firm handles your initial adaptation or ongoing consulting, the exam for those years must be signed by a different, independent expert.
• The incompatibility looks backwards and forwards (3 + 3 years): decide calmly who will do what over the coming years, rather than solving it every December.
• When requesting a quote, ask expressly: have you provided, or will you provide, any other paid services to us? The answer should be clear before you commission anything.

Legal basis:

• Art. 28.2 of Ley 10/2010

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

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• What the external expert exam is
• The three-year cycle
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