Are foundations and associations obliged entities?

Yes, under a special regime. Foundations and associations do not carry the full package of Ley 10/2010, but they are not outside it either: article 39 of the law and article 42 of the Regulation impose obligations of their own — identifying those who contribute and those who receive funds, keeping the documentation, and cooperating with SEPBLAC by reporting suspicions and answering official requests.

What the rules do not require of them: the annual external expert exam and the formal training plan are not mandatory under the special regime. What is worth having anyway: a simple procedure for identifying donors and beneficiaries, written criteria for donations in cash or from abroad, and a basic training session for whoever manages funds — because the duty to detect and report suspicions does exist, and because a non-profit's reputation is its main asset.

We work with foundations precisely at that middle point: light, proportionate adaptation, without turning an NGO into a bank.

Legal basis and official sources:

• Art. 39 of Ley 10/2010
• Art. 42 of RD 304/2014

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?
• Other special cases
• AML training
• All frequently asked questions