FAQs · The external expert exam
The report is not free-format: Order EHA/2444/2007 sets its structure, and the inspection expects to find it.
The report follows the structure of Order EHA/2444/2007 — in force insofar as it does not conflict with the 2014 Regulation —: general details of the entity, the expert and the previous report; a detailed description and assessment of the internal control measures, area by area; and proposed corrections. It must be issued promptly, and no later than two months after the reference date.
The areas the expert reviews and assesses include: internal rules (manual and procedures), control bodies (the internal control body and the representative), customer due diligence and identification, record keeping, detection and analysis of unusual or suspicious transactions, reports to SEPBLAC, handling of official requests, staff training and, where applicable, subsidiaries, branches, agents and intermediaries.
The assessment is twofold: the theoretical soundness of each procedure (is it well designed?) and its practical operation (does it actually work?). An impeccable manual that nobody applies is exposed by the second.
The report is confidential — it remains at SEPBLAC's disposal, it is not published — and the deficiencies must reach the governing body within three months at most. A tip: when changing experts, hand the new one the previous report; they need it for the follow-up, and it signals a well-run process.
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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