FAQs
Clear answers on obliged-entity status, the annual external audit and the obligations set out in Ley 10/2010.
Obliged entities are the individuals and legal entities listed in paragraphs a) to y) of art. 2.1 of Ley 10/2010, Spain's law on the prevention of money laundering and terrorist financing.
Compliance with the obligations set out in Chapters II, III and IV of the law: customer due diligence, reporting obligations and internal procedures (reporting suspicious transactions, appointing a representative to SEPBLAC, training employees, and more).
Broadly, yes: Ley 10/2010 sets out a common regime for all obliged entities. Its implementing regulation, RD 304/2014, provides for certain exceptions and particularities depending on the entity's activity and size, which are worth reviewing case by case.
Entities carrying out the activities listed under art. 2.1 must undergo an annual review by an external expert, carried out by professionals registered with SEPBLAC's Special Register. Our auditors have held that registration since 2010.
Sole traders and individual professionals, insurance brokers, and entities under art. 2.1 i) to u) with fewer than 10 employees and turnover or balance sheet below 2 million € (unless they belong to a group that exceeds those figures).
It is classified as a serious infringement (infracción grave): a fine ranging from 60.001 € up to 1% of the entity's own funds, plus possible sanctions against the directors and officers responsible.
Yes, under a special regime: this is set out in art. 39 of Ley 10/2010 and art. 42 of its implementing regulation, RD 304/2014, with obligations adapted to their non-profit nature.
Yes. The law requires obliged entities to train their executives and employees in AML prevention. We deliver general and specific courses, in person or online, and issue an accrediting certificate for SEPBLAC in the event of an inspection.