FAQs · SEPBLAC procedures
A monthly obligation — but only for some obliged entities. Confusing it with suspicious transaction reports is the classic mistake.
Systematic reporting — known as DMO, the monthly declaration of operations — is the obligation under article 20 of Ley 10/2010 to report to SEPBLAC each month the operations that meet certain objective criteria. It applies only to obliged entities under letters a) to i) of article 2.1 (essentially, the financial sector), with exceptions such as insurance brokers and financial advisory firms. The generality of non-financial obliged entities — real estate, advisers, jewellers, art, the trade in goods — does not file DMO.
DMO is not the same as reporting a suspicion. It is the confusion we find most often: the suspicious transaction report (art. 18) must be made by any obliged entity when it detects a suspicious operation, at any time and with no negative declarations; systematic reporting is periodic, objective (by type and amount of operation, art. 27 of the Regulation) and reserved to financial-sector entities.
Deadlines. Declarations are filed between the 1st and the 15th of each month, for the previous month's operations. And an obligation many overlook: if a calendar half-year brings no reportable operations, a negative declaration is due between the 1st and the 15th of the month following that half-year.
How it is filed today. Through the DMO software application, downloaded from SEPBLAC's own website, which requires a digital certificate issued by the Bank of Spain. (If your manual still mentions the CD the Executive Service used to send out, that alone tells you it needs updating.) Late declarations additionally require a written justification from the representative or their authorised person, filed electronically through the electronic registry of the Bank of Spain's Virtual Office.
In practice: if your company is not a financial institution, your obligation is most likely not the DMO but having suspicious-transaction detection and reporting properly set up — which we do review in every external expert exam.
Legal basis and official sources:
Reviewed: August 2026 · PBK Asesores — external experts in AML/CTF before SEPBLAC since 2010, more than 900 exams performed.
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