What penalties does Ley 10/2010 provide — and who is liable?

The law penalises by tier: serious infringements carry fines from €60,000, and very serious ones from €150,000, with maximums that — depending on the case — reach €5 million and €10 million, 10% of annual turnover or multiples of the economic content of the transaction. Minor infringements go up to €60,000. And it is not only the company that answers: the directors and managers responsible can be fined and disqualified personally.

• Minor: private reprimand and a fine of up to €60,000.
• Serious — this is where, for instance, failing to undergo the external expert exam when it is required falls —: a fine from €60,000 up to the greatest of: €5,000,000, 10% of annual turnover, the economic content of the transaction plus 50%, or three times the profit derived from the infringement; together with public or private reprimand. For the directors or managers responsible: a fine of €3,000 to €5,000,000 and disqualification for up to five years.
• Very serious: a fine from €150,000 up to the greatest of: €10,000,000, 10% of turnover, twice the transaction or five times the profit; for the individuals responsible, a fine of €60,000 to €10,000,000 and disqualification for up to ten years.

Two details that weigh more than the figures: a public reprimand is published — with the reputational damage that entails — and the penalty arrives together with an order to correct the conduct, that is, the compliance cost you tried to avoid, now under supervision.

The useful reading is not fear but contrast: the annual cost of keeping the system in order — a living manual, an appointed representative, accredited training and the annual exam — is a small fraction of the sanctions floor. It is, literally, the evidence of diligence you produce when an inspection arrives.

Legal basis:

• Arts. 50 to 62 of Ley 10/2010 (esp. arts. 56 and 57, amounts after RD-ley 11/2018)

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:

• The external expert exam
• Is your company an obliged entity?
• Mandatory AML training
• All frequently asked questions