On entry
The casino identifies everyone who seeks to enter the premises, verifies their identity with reliable documents and records it.
AML for casinos and gambling operators in Spain
Casinos and gambling operators are obliged entities under Law 10/2010 (Art. 2(1)(p)), with a special due diligence regime: identification on entry, a €2,000 threshold and reporting to SEPBLAC. We help you set up and maintain your AML system.
Do you run a casino or gambling business?
Tell us about your situation and we will guide you on your AML obligations.
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- Due diligence threshold
- €2,000
- Casinos as obliged entities
- Art. 2(1)(p)
- Core legislation
- Law 10/2010
- Implementing regulation
- Royal Decree 304/2014
Why it affects you
Casinos and gambling: obliged entities
The gambling sector handles cash, prizes and fast movements of funds, which makes it especially vulnerable to money laundering. That is why Law 10/2010 lists casinos among obliged entities (Art. 2(1)(p)) and imposes a specific due diligence regime on them.
The anti-money laundering supervisor is SEPBLAC. In parallel, the sector has its own regulator (the Directorate General for the Regulation of Gambling, for gambling at national level). Land-based casinos and online operators share the duty to prevent money laundering, with differences depending on their activity.
Law 10/2010 · Art. 2(1)(p)
Art. 7 · Due diligence
Royal Decree 304/2014
Special regime
When you must identify the customer
A casino has its own identification points, which go beyond general due diligence. These are the main ones.
In chip or check transactions
When handing over checks for winnings, on purchases or sales of chips for significant amounts and on gambling-related transfers.
From €2,000
On transactions of €2,000 or more (in one transaction or several linked ones), also applying the remaining due diligence measures.
A useful feature: when the casino correctly applies the identification measures on entry and in these transactions, the law allows the general due diligence measures to be treated as fulfilled. But any indication of money laundering always requires action, regardless of any threshold.
What the law requires
Your AML obligations
In addition to the special identification regime, casinos and gambling operators must comply with the general set of obligations under Law 10/2010.
Due diligenceFormal customer identification, identification of the beneficial owner, the purpose of the relationship and ongoing monitoring, scaled to the risk.
Special examinationAnalyze complex or unusual transactions, or transactions with no apparent economic purpose, that may be linked to money laundering.
Reporting to SEPBLACReport suspicious transactions when there are indications of money laundering, and handle systematic reporting and requests for cooperation.
Internal control and manualApprove an AML manual, appoint a SEPBLAC representative and, where applicable, set up an internal control body.
Record keepingKeep identification and transaction records for the statutory period of ten years.
Staff trainingAn ongoing training plan so your team knows how to spot red flags and apply the procedures.
Online gambling: remote gambling operators are also obliged entities and face their own challenges (remote identification, e-wallets, payments and traceability of funds), which require due diligence to be adapted to the digital channel. Any indication of money laundering requires measures to be applied, regardless of any threshold or exception.
Specialist support
How we help you
We help casinos, gaming halls and online gambling operators implement and maintain an AML system that stands up to an inspection.
Manual and procedures
We draft the AML manual and the identification procedures, tailored to your activity (land-based or online).
Risk analysis
We prepare the operator’s risk analysis and the list of high-risk transactions specific to the gambling sector.
Training and support
We train your staff, support your SEPBLAC representative and assist you with inspections and reports.
Is your casino or gambling business AML compliant?
We review your AML system, adapt it to your activity and stand by you in your dealings with SEPBLAC.
Frequently asked questions
AML for casinos and gambling: common questions
Are casinos obliged entities?
Yes. Casinos are expressly listed as obliged entities in Article 2(1)(p) of Law 10/2010, with a special due diligence regime adapted to their activity.
Who must be identified in a casino?
The casino must identify everyone who seeks to enter the premises, verify their identity with reliable documents and record it. It must also identify customers in certain transactions (checks for winnings, significant purchases or sales of chips, transfers).
What is the €2,000 threshold?
Land-based gambling operators apply due diligence measures when they carry out transactions of €2,000 or more, in one transaction or several linked ones (Article 7 of Law 10/2010).
Is online gambling also covered?
Yes. Remote gambling operators are also obliged entities and must adapt due diligence to the digital channel: remote identification, e-wallets, payment methods and traceability of funds.
Do I need a manual and a SEPBLAC representative?
Yes. As an obliged entity, you must approve an AML manual, appoint a SEPBLAC representative and, depending on your size, set up an internal control body. Learn more on our AML manual page.
What if I detect a suspicious transaction?
You must carry out a special examination and, if the indication is confirmed, report it to SEPBLAC without delay. You must not disclose this to the customer. More details on suspicious transaction reporting.
Are any games excluded?
The rules allow certain games of chance that present a low risk of money laundering to be excluded by regulation, in whole or in part. It is best to confirm case by case whether this applies to your specific activity.
Who supervises compliance?
SEPBLAC is the anti-money laundering supervisor. The sector also has its own gambling regulator (the Directorate General for the Regulation of Gambling, at national level).
Contact
Book a call
Tell us about your situation and we will guide you on the anti-money laundering obligations of your casino or gambling business.
Anti-money laundering in the gambling sector
The gambling sector is one of the most closely watched in anti-money laundering, because of cash handling, the speed of transactions and the flow of prizes. Law 10/2010 lists casinos among obliged entities (Art. 2(1)(p)) and applies a special due diligence regime to them.
Identification and threshold
Casinos identify everyone who seeks to enter the premises, verify their identity with reliable documents and record it. They also identify customers in transactions such as handing over checks for winnings or significant purchases and sales of chips. In addition, land-based gambling operators apply due diligence measures to transactions of €2,000 or more (Article 7 of Law 10/2010), whether in one transaction or several linked ones.
General obligations
Alongside the above, casinos and operators must comply with the general set of obligations under the law: due diligence (including the beneficial owner), special examination, reporting to SEPBLAC of suspicious transactions, internal control with a manual, a representative and, where applicable, an internal control body, record keeping and staff training.
Online gambling and exclusions
Remote gambling operators are also obliged entities and must adapt their controls to the digital environment (remote identification, e-wallets, payment methods). The rules allow certain low-risk games to be excluded by regulation. In any case, any indication of money laundering requires action, regardless of any threshold or exemption.
Anti-money laundering
AML by sector
Roles and resources
Official sources
Key legislation, linked to the official text:
- Law 10/2010 of April 28 on the prevention of money laundering and terrorist financingBOE · consolidated text
- Royal Decree 304/2014 of May 5 approving the Regulation implementing Law 10/2010 of April 28 on the prevention of money laundering and terrorist financingBOE · consolidated text
Legislation and links reviewed in .