AML for Jewelers and Precious Metals Dealers in Spain

Last updated: August 4, 2026

Anti-money laundering for jewelers, cash-for-gold shops and precious metals dealers

Dealing in jewelry, precious stones and precious metals is one of the sectors that Law 10/2010 of April 28 on the prevention of money laundering and terrorist financing includes in its Article 2 for a specific reason: these are high-value goods, easy to carry and with a very liquid second-hand market. In practice, a neighborhood jewelry store can be subject to the same set of obligations—manual, due diligence, suspicious transaction reporting—as a financial institution, except that it has no compliance department to deal with them. This page translates that framework into day-to-day counter operations.

When a jewelry store becomes an obliged entity

The key is not the product: it is the payment method. Traders in goods become subject to Law 10/2010 when cash payments reach the amount set by the regulations, calculated as those regulations provide. That is why two identical jewelry stores can be in different positions: the one that only accepts card and bank transfer is, as a general rule, outside the regime through this route; the one that accepts banknotes for pieces of a certain value is fully in. On top of this there is a second rule that is often confused with the first: the legal limit on cash payments when a business or professional is involved, which is a separate tax obligation, with its own penalty regime, and does not replace due diligence. Before setting anything up, you should put the business’s cash acceptance policy in writing and configure it at the till: it is the decision that shapes the rest of the system. We review it with you in the first consultation and tell you whether or not you are on the list of obliged entities.

What is required at the counter and what must be kept on file

Due diligence comes down to three steps that fit into one minute of a sale. Identify the customer with a valid document and keep a copy. When the buyer is a company, check who is behind it: the beneficial ownership of that company, because a tax ID (CIF) identifies no one. And understand the transaction, asking about the source of funds when the amount or the context justifies it. The rules scale these checks: there are cases of simplified due diligence and cases of enhanced due diligence, for example with politically exposed persons or high-risk customers. All of this is documented in a record for each customer, linked to the invoice, kept for the legal period and stored in an organized, easy-to-locate way. You should also plan for the awkward case: a transaction that does not fit the profile of the person carrying it out, which requires you to examine it, consider the duty to refrain and, if the suspicion remains, report it to SEPBLAC confidentially and without alerting the customer. The rule that sums up the sector is simple: in anti-money laundering, what is not documented did not happen, however well it was done at the time.

Who is responsible within a family business

Law 10/2010 does not require a department: it requires identifiable responsible persons. That means a written manual with the business’s real procedures, a self-assessment of its own risk, an internal control body or officer depending on the size of the company, and a formally appointed SEPBLAC representative who signs the reports and handles requests for information. Add to that training for customer-facing staff—with an attendance list and certificate, because it is the first thing you will be asked to prove—and a review of the system by an external expert as required by the regulations. If you also sell remotely, there is one more piece: non-face-to-face identification, whose video methods are regulated by Order ETD/465/2021 and whose evidence must be kept. In a family business these roles usually fall to the owner, who already handles purchasing, the till and the workshop, which creates an obvious practical problem: nobody has the time. That is why many stores outsource the role to an external SEPBLAC representative and commission a tailored AML manual instead of improvising one from a template.

What happens if an inspection arrives, and where the rules are heading

SEPBLAC action almost always starts with a request for information: the current manual, the risk self-assessment, the appointment of responsible persons, training records, customer records for specific transactions and the external expert review. What is assessed is whether those documents existed before the request and whether the system was actually being applied. Infringements of Law 10/2010 are classified as minor, serious and very serious, with penalties ranging from a private reprimand to fines and public reprimands; the proceedings are investigated by SEPBLAC and decided by the competent body depending on the severity. Meanwhile, the EU AML package—Regulation (EU) 2024/1624, Directive (EU) 2024/1640 and Regulation (EU) 2024/1620 establishing the AMLA authority—is moving forward with phased application and is being implemented: it will harmonize obligations and raise the bar for traders in high-value goods. Preparing now is cheaper than redoing it later; if you already have a request for information on your desk, start with SEPBLAC inspection.

This content is for general information purposes only and does not constitute legal advice. The legislation cited may have been amended after the update date shown: always check the version in force or contact us to analyze your specific case.