If your entity exceeds €50 million in turnover or €43 million in balance sheet total, Article 35(3) of the implementing regulation of Law 10/2010 requires you to have a technical unit that analyzes information with specialized staff dedicated exclusively to it. Not having one is a serious infringement. We design it with you and get it ready for SEPBLAC. If you would rather outsource it, we explain how in AML technical unit outsourcing.
Do you need a technical unit? Free assessment
Tell us what type of obliged entity you are, your size and how you analyze alerts today, and we’ll tell you what you are missing.
The law says what the technical unit must have, not how to organize it. We help you decide its size, its place in the organization chart and its procedures, and put in place the evidence SEPBLAC will ask for.
We check your turnover and balance sheet figures against the criteria of Commission Recommendation 2003/361, to which Article 31(3) of the implementing regulation refers, including partner and linked enterprises.
We define where the technical unit sits, who it reports to, how it works with the SEPBLAC representative and the internal control body, and how it is kept separate from internal audit.
We work out how many people you need based on your alert volume and your business risk, and we define the staff profile and the training plan in analysis that Art. 35(3) requires.
We write down the workflow: receiving and prioritizing alerts, analysis, the written special examination, the proposal to the representative and a documented decision on reporting to SEPBLAC.
We review the scenarios and thresholds of your monitoring tool so that the technical unit analyzes what matters and does not drown in false positives.
We reflect the technical unit in the AML/CFT manual, prepare its reports to the internal control body and organize the documentation for the external expert and for inspections.
The obligation depends on the size of the obliged entity. These are the moments when you should not wait.
If your turnover exceeds €50 million or your balance sheet total exceeds €43 million, the technical unit is no longer optional.
The external review under Article 28 of Law 10/2010 examines the internal control bodies: a unit without exclusive dedication or without training shows up as a deficiency.
When facing a request for information or an inspection, you will have to show who analyzes the alerts, with what resources and with what results.
From July 10, 2027, Regulation (EU) 2024/1624 requires a compliance officer with sufficient seniority and adequate resources: a good technical unit is their natural support.
Figures from Law 10/2010 and its implementing regulation, approved by Royal Decree 304/2014.
Annual turnover above which the obliged entity must have a technical unit.
Annual balance sheet total that, on its own, also triggers the obligation.
Failing to set up adequate internal control bodies, including technical units, is a serious infringement.
Minimum fine for a serious infringement. It can rise to the highest of several amounts, such as 10% of turnover or €5 million.
Minimum fine for each responsible director or senior manager. It can reach €5 million.
The AML bodies operate with functional separation from the internal audit department.
We review its structure, team and procedures and give you a list of changes in order of urgency.
It is the team in charge of processing and analyzing information on anti-money laundering and counter-terrorist financing. It is required by Article 35(3) of Royal Decree 304/2014, which implements Article 26 ter(7) of Law 10/2010, and it must have specialized staff, dedicated exclusively to it and with appropriate training in analysis.
Obliged entities whose annual turnover exceeds €50 million or whose annual balance sheet total exceeds €43 million. Exceeding either figure is enough. The thresholds are interpreted using the criteria of Commission Recommendation 2003/361 concerning the definition of SMEs (Article 31(3) of the implementing regulation).
The internal control body is responsible for applying the AML policies and procedures, and it meets and keeps minutes of its resolutions (Article 26 ter(4) of Law 10/2010). The technical unit is the specialized team that analyzes the information: it reviews alerts, carries out the special examination and prepares proposals. The SEPBLAC representative is responsible for the reporting obligations to the Executive Service.
The law requires its staff to be dedicated exclusively to it, so they should not split their time with commercial or operational functions. In addition, the AML bodies must operate with functional separation from internal audit (Article 26 ter(6) of Law 10/2010).
The law does not set a number. It depends on the volume of customers and transactions, the risk of your business and the alerts your systems generate. What it does require is the necessary resources: failing to provide the representative and the internal control body with resources is a serious infringement (Article 52(1)(o) of Law 10/2010).
Spanish law does not specifically regulate it, and Article 35(3) of the implementing regulation requires specialized staff dedicated exclusively to the unit, so it should be analyzed carefully. You can reinforce the technical unit with an external team for analysis, training or tools while keeping the decisions within your entity, and from July 10, 2027 Article 18 of Regulation (EU) 2024/1624 will regulate the outsourcing of tasks. We explain it in AML technical unit outsourcing.
Failing to set up adequate internal control bodies, including technical units, is a serious infringement (Article 52(1)(ñ) of Law 10/2010). The minimum fine is €60,000 and it can rise to the highest of several amounts, such as 10% of annual turnover or €5 million. The responsible directors and senior managers can also be sanctioned.
Regulation (EU) 2024/1624, applicable from July 10, 2027, organizes internal control around a member of the management body responsible for implementing the rules and a compliance officer with sufficient seniority, who will report suspicious transactions to the financial intelligence unit. A properly sized technical unit makes that transition easier.
A useful technical unit shows in the quality of its analysis and in the traceability of each decision, not in the organization chart.
Turnover, balance sheet total and linked enterprises determine whether you need one.
Prioritized alerts, a written special examination and a reasoned proposal to the representative.
The manual, the minutes of the internal control body, reports and training show that the unit works.
Source: Law 10/2010 (Arts. 17, 18, 26 ter, 52 and 57), Royal Decree 304/2014 (Arts. 31, 33 and 35) and SEPBLAC Recommendations on internal control measures.
These terms appear in Law 10/2010, in Royal Decree 304/2014 and in any SEPBLAC inspection.
Team specialized in processing and analyzing anti-money laundering information.
Responsible for applying the AML policies and procedures; it meets and keeps minutes of its resolutions.
Responsible for complying with the reporting obligations to the Executive Service.
Written analysis, with its conclusions, of facts or transactions that may be related to money laundering.
Report to SEPBLAC of the transactions in which, after the special examination, there is an indication or certainty of money laundering.
Warning generated by the monitoring system when a transaction or a customer matches a risk scenario.
Technical unit staff do not split their time with other functions.
The AML bodies operate separately from the internal audit department.
Document setting out the internal control procedures, including how the control bodies work.
Technical unit: entities with more than €50 million in turnover or €43 million in balance sheet total.
Internal control body: all obliged entities, except in the cases set out in Article 35(2) of the implementing regulation.
Technical unit: analyzing the information: alerts, special examination and proposals.
Internal control body: applying the AML policies and procedures and adopting resolutions.
Technical unit: specialized staff dedicated exclusively to the unit.
Internal control body: with representation, where applicable, of the different business areas.
Technical unit: written analysis and special examination.
Internal control body: minutes of each meeting with the resolutions adopted.
Technical unit: serious infringement (Article 52(1)(ñ) of Law 10/2010).
Internal control body: serious infringement (Article 52(1)(ñ) of Law 10/2010).
These failings show up as soon as the special examination files are reviewed.
Tell us what type of obliged entity you are, your turnover and balance sheet figures and how you analyze alerts today, and we’ll tell you what your technical unit needs.
Updated October 15, 2026
Law 10/2010 on the prevention of money laundering and terrorist financing leaves it to the implementing regulation to decide which obliged entities must have technical units for processing and analyzing information (Art. 26 ter(7)). Royal Decree 304/2014 sets this out in its Art. 35(3).
Obliged entities whose annual turnover exceeds €50 million or whose annual balance sheet total exceeds €43 million. The thresholds are interpreted in accordance with Commission Recommendation 2003/361 (Article 31(3) of the implementing regulation). Below those figures it is not mandatory, although the internal control body is, except in the cases set out in Art. 35(2).
The technical unit must have specialized staff, dedicated exclusively to it and with appropriate training in analysis. The AML bodies must have the necessary material, human and technical resources (Article 26 ter(5) of the Law) and operate with functional separation from internal audit (Article 26 ter(6)). The SEPBLAC Recommendations on internal control measures also ask that the AML/CFT manual describe its reporting line, functions, staff and dedication.
It analyzes the alerts from the monitoring systems, carries out the special examination of the transactions that require it and prepares the suspicious transaction reports on which the SEPBLAC representative decides. Its work is documented in writing and reviewed in the external expert report.
Royal Decree 813/2026 amends Article 35(1) of the implementing regulation: from October 28, 2026, the representative and up to two authorized persons (three in groups) are proposed by means of a formal self-declaration (declaración responsable). The technical unit requirement in Art. 35(3) does not change.
The technical unit is one part of the entity’s anti-money laundering system and the natural support for the compliance officer that the EU AMLR will require from July 2027.