When must a suspicious transaction be reported to SEPBLAC?

The legal sequence is: detect an unusual transaction → subject it to special examination (art. 17) → if the examination shows indication or certainty of a link to money laundering, terrorist financing or their predicate offences, report it to SEPBLAC on your own initiative and without delay (art. 18) — and refrain from executing it (art. 19). This obligation reaches all obliged entities, from the bank to the neighbourhood estate agency.

Do I have to file anything if there is nothing suspicious?

No. There are no negative declarations for suspicious transaction reports — 'just in case' does not exist here. The periodic negative declaration belongs to systematic reporting (DMO), and only for certain financial-sector entities.

How to report a suspicious transaction to SEPBLAC

The legal sequence is: detect an unusual transaction → subject it to special examination (art. 17) → if the examination shows indication or certainty that it is linked to money laundering, to terrorist financing or to their predicate offences, report it to SEPBLAC on your own initiative and without delay (art. 18) — and refrain from executing it (art. 19). This obligation reaches ALL obliged entities, from the bank to the neighbourhood estate agency.

What is reported. The report contains the identification of those involved, the activity examined, the steps taken and the grounds for suspicion. It is filed using the suspicious transaction report form through SEPBLAC's channel (the procedure is published on its website), signed by the representative before SEPBLAC — one more reason why having one appointed is not optional.

Three rules that save you trouble:

No negative declarations. Nothing is filed if there is nothing suspicious — the "just in case" does not exist here. The periodic negative declaration belongs to the DMO, and only for certain financial-sector entities.
Refrain from executing the suspicious transaction before reporting; where refraining is not possible or could hinder the investigation, the rules themselves provide how to act — one of the points worth having written into the manual before it happens.
Prohibition of disclosure (art. 24): neither to the customer nor to third parties. The "friendly heads-up" turns whoever gives it into an offender.

The standard that protects you is not reporting a lot, but being able to prove your judgement: a documented special-examination file, a reasoned decision (whether or not you report) and the role of the manual as applied. That is exactly what we reconstruct with clients in every annual exam.

Legal basis and official sources:

Arts. 17, 18, 19 and 24 of Ley 10/2010
Suspicious transaction report procedure: sepblac.es (verified Aug 2026)

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:

How to report a suspicious transaction (comunicación por indicio)