FAQs · SEPBLAC procedures
They are your company's interlocutor with the supervisor — and the first thing an inspection checks exists.
The representative before SEPBLAC is the person through whom the obliged entity communicates with the supervisor: they sign the reports, receive official requests and answer for the information arriving. They must hold a management or executive position in the company (for sole traders, it is the owner), and the appointment is made by proposing them to SEPBLAC with form F22 — today signed electronically and filed through the electronic registry of the Bank of Spain's Virtual Office.
What is filed. Together with the F22: the certificate of the governing body's resolution appointing them, the representative's identification (copy of the DNI or NIE/passport) and a description of their professional background (a CV works). Sole traders file only the F22 and a copy of their identity document. A detail that saves paperwork: no notarised deeds are required — the appointment resolution is a private document, with no need to raise it to a public deed, provided it expressly mentions the role of "representative before SEPBLAC".
When. From the moment the company holds obliged-entity status — not when the first report needs filing. SEPBLAC may raise reasoned objections or observations about the person proposed.
The authorised person (F22-6). The representative may empower up to two people to act on their behalf before SEPBLAC using form F22-6, signed by both. Mind what this implies: everything the authorised person does is deemed done by the representative, for all purposes. The authorisation is indefinite and its revocation must be notified.
Changes and cessation. Any change in the notified details is processed with a new F22 (or F22-6); the cessation of the representative or the authorised person is notified in writing stating the reason — also when the company ceases its activity.
The two failures we see most in our exams: obliged entities operating for years with no representative appointed (believing "that is for banks"), and representatives appointed a decade ago who no longer work at the company. Both are exposed in the first minute of an inspection — and both are fixed within a week.
Legal basis and official sources:
Reviewed: August 2026 · PBK Asesores — external experts in AML/CTF before SEPBLAC since 2010, more than 900 exams performed.
Need to put this in order? Tell us your case → Contact · +34 91 110 28 29
Related: