The Autoridad Nacional de Integridad Financiera (National Financial Integrity Authority) is the body Spain is going to create to concentrate anti-money laundering supervision, which is currently split among several players. It absorbs SEPBLAC, is being built by transforming the FROB (Spain’s bank restructuring fund) and comes with powers that no Spanish authority has had until now: suspending transactions and blocking accounts. This page explains what changes for an obliged entity, and when.
How ANIFI affects your entity
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ANIFI is not one more layer on top of the current system: it is a reorganization. On July 28, 2026, the Council of Ministers approved at first reading the draft bill (anteproyecto) that creates it, and its public consultation is still open. It should be read for what it is (a text still going through the legislative process) but also for what it anticipates: a single supervisor, with more resources and the power to intervene directly.
ANIFI is the National Financial Integrity Authority (Autoridad Nacional de Integridad Financiera) provided for in the draft Bill on comprehensive measures for the prevention of money laundering, terrorist financing and the financing of the proliferation of weapons of mass destruction.
It is set up as an independent body and brings together functions that are currently spread out: financial intelligence, supervision, inspection, sanctioning powers and international financial sanctions.
SEPBLAC is merged into the new authority. Its functions do not disappear: they change hands and are combined with others currently performed by the Treasury and the Ministry of Economy.
ANIFI is also being built on the structure of the FROB, which will no longer act as the bank resolution authority or manage public shareholdings.
The diagnosis behind the reform is that anti-money laundering in Spain was fragmented: the body that received the information was not the one that supervised, and the one that supervised was not always the one that imposed sanctions. ANIFI closes that loop.
| Function | Where it sits today | What the change means |
|---|---|---|
| Financial intelligence unit | SEPBLAC | Analysis of suspicious transaction and suspicious activity reports moves to the new body, with more resources and with access to supervisory information. |
| Supervision and inspection | SEPBLAC and sectoral supervisors | A single point of contact for AML compliance inspections, with consistent criteria across sectors. |
| Sanctioning powers | Ministry of Economy, on SEPBLAC’s proposal | The authority that detects the breach is the one that sanctions it, without the intermediate step that currently drags proceedings out. |
| International financial sanctions | Treasury and Ministry | Freezing of funds and restrictive measures are managed by the same body that supervises AML compliance. |
| Proliferation financing | Split | Expressly brought within scope, in line with the approach of the EU package. |
| Registers and beneficial ownership | Several registers | Coordination of beneficial ownership information, one of the areas that Directive (EU) 2024/1640 requires to be strengthened. |
Summary table based on the draft bill submitted to public consultation and on the official summary of the Council of Ministers meeting. The final allocation may change during the parliamentary process.
The change of supervisor is a good excuse to review what many obliged entities have been dragging along for years. An outdated manual or a risk self-assessment that nobody has touched since it was approved is exactly the kind of finding that an authority with more resources will spot sooner.
We test your manual, your risk self-assessment, your due diligence procedures and your reporting history against what the new framework will require. The goal is to reach ANIFI’s first inspection with no surprises.
The Spanish reform does not come alone: it implements Regulation (EU) 2024/1624 and transposes Directive (EU) 2024/1640. We align your system with the EU framework so you do not have to do the work twice.
Appointment, duties, independence and relationship with the new supervisor. We also check whether your control structure meets the bar set by the EU package.
Inspection preparation, responses to requests for information and defense in sanctioning proceedings. With sanctioning powers concentrated in one body, timeframes and criteria change.
Review of your detection, analysis and reporting procedure, and of the quality of what you actually report. It is the first thing any supervisor looks at.
A verifiable annual training plan, tailored to the real risk profile of your business. Generic training with no records is a recurring inspection finding.
This is the fundamental change. Until now, the system’s response to a suspicious transaction was essentially informational: it was reported and then everyone waited. The draft bill gives ANIFI the power to intervene directly in transactions, by suspending transactions and blocking accounts.
| Action | What the authority asks for | What you must be able to show |
|---|---|---|
| Request for information | Documents on a client, a transaction or a procedure. | That you can retrieve the full file for that transaction on time, with the information you had in front of you on the day it was executed. |
| Inspection | Review of the AML/CFT system as a whole. | A living manual, an up-to-date risk self-assessment, documented training, and consistency between what the procedure says and what operations actually do. |
| Suspension of a transaction | Stopping a specific transaction before it is executed. | Real technical capability to stop a transaction in progress, and an internal procedure that says who decides and how quickly. |
| Blocking of accounts | Immobilizing funds linked to an investigation. | Traceability of the funds and of the business relationship, and a channel of communication with the authority that works outside office hours. |
| Sanctioning proceedings | Determining the obliged entity’s liability. | That the breach, if there was one, was one-off and not structural: the difference between a sanction and a licensing problem. |
Description based on the draft bill currently going through the legislative process. The exact scope of each power and its procedural safeguards must be confirmed against the text finally adopted.
Four milestones between the adoption of the EU package and the moment ANIFI starts inspecting.
Regulation (EU) 2024/1624, Directive (EU) 2024/1640 and Regulation (EU) 2024/1620 rewrite the EU framework, harmonize obligations in a directly applicable regulation and create the EU authority.
First reading of the draft Bill on comprehensive measures for the prevention of money laundering, terrorist financing and proliferation financing. This is the text that creates ANIFI and widens the scope of obliged entities.
Process open for submitting comments on the draft bill to the Ministry of Economy. It is the window in which a sector can still influence the text: for certain sectors, whether they fall within scope or not is decided here.
The date from which the AMLR applies generally. The Spanish timeline should be settled before then, because the EU regulation applies directly regardless of the status of the national law.
Professional football clubs and football agents have an additional period. We cover this on our page on anti-money laundering for football clubs.
If your entity is already an obliged entity, ANIFI does not add new obligations by itself: the obligations come from the EU Regulation. What changes is who is watching you, with what resources and with what consequences.
| Aspect | Current situation | With ANIFI |
|---|---|---|
| Point of contact | SEPBLAC for intelligence; the sectoral supervisor for part of the supervision. | A single body to report to, to be supervised by and, where applicable, to be sanctioned by. |
| Timeframes for proceedings | The sanction proposal and the decision are in different hands. | The procedure is concentrated in the same authority, with proceedings likely to move faster. |
| Ability to react | Essentially informational: you report and wait. | Direct intervention in transactions through suspension of transactions and blocking of accounts. |
| Supervisor’s resources | A limited structure relative to the number of obliged entities. | A body with its own funding through fees, with the FROB’s structure behind it. |
| European coordination | Relations with the EU authorities through several channels. | Dealings with the EU anti-money laundering authority from a single point. |
| Supervised scope | Obliged entities under Law 10/2010. | The new obliged entities from the EU package are added: crypto-assets, crowdfunding, high-value goods and, from 2029, professional football. |
An authority with more resources does not uncover new breaches: it uncovers the ones that were already there, sooner. These are the six we find most often when reviewing AML/CFT systems that have not been touched for a while.
Template manual: a manual that does not describe the entity’s real operations is an immediate finding. The point is not that the text is correct, but that the people who work there recognize it.
Frozen risk self-assessment: approved years ago and never reviewed, even though products, channels and the type of client have changed. It is the piece on which the rest of the system rests.
Bare-minimum reporting: a very low volume of suspicious transaction reports for the entity’s size and profile is a signal that any supervisor will cross-check against its own sector data.
Generic courses, with no attendance records or assessment, and not tailored to the real risk profile. For inspection purposes, training that cannot be evidenced is the same as training never given.
Client files with corporate structures that are not traced through to the natural person. Directive (EU) 2024/1640 strengthens precisely this point.
An entity without the technical capability to stop a transaction in progress will not be able to comply with a suspension order, and that operational failure is attributable to it.
We review your manual, your risk self-assessment, your procedures and your reporting history, and give you a report on what a supervisor with more resources would find first.
REGULATORY CONTROL CENTER · PREPARING FOR ANIFI
The change of supervisor does not weigh the same on every obliged entity. A financial institution starts from a mature system; a professional firm or a real estate agency, from a much lighter one; a crypto-asset operator, from one that has only just been built. This panel shows where it makes sense to start.
An indicative reference to prioritize the work and size the project team.
None of them is a mistake in interpreting the law. They are all management mistakes, and they are all paid for at the first inspection.
The content of the EU package has been known and stable since 2024, and the Spanish draft bill since July 2026. Starting when the law appears in the BOE (Official State Gazette) squeezes all the work into the worst moment, when every law firm and provider is overloaded.
The obligations come from the EU Regulation, not from the body. Anyone who reads the reform as a change of acronym rather than a change in what is required will prepare for the wrong thing.
The process is open until September 30, 2026. For sectors debating their own scope or their thresholds, it is the only real window to influence the text.
Updating the document without checking what the team really does produces a flawless manual and a non-compliant entity. The contradiction between the two is what inspections detect.
If the authority can order a transaction to be suspended, the entity must be able to do it. It is worth checking how long it really takes to stop a transaction in progress and who is authorized to make that decision.
A generic course with no records or assessment proves nothing. Training must match the entity’s risk profile and leave retrievable evidence of who received it and when.
Three principles that separate entities that face an inspection calmly from those that face it by improvising.
The manual, the risk self-assessment, the procedures and what the team does every day must describe the same entity. The most cost-effective review of all is to read the whole system looking for contradictions.
Training with records, documented client acceptance decisions, and transaction analyses filed and retrievable. For inspection purposes, what exists but cannot be shown is the same as what does not exist.
A blocking procedure that nobody has ever executed is not a procedure: it is a piece of text. Test it, time it and keep a record of the test.
If you would like a prior review of your AML/CFT system, see our AML services or request a free consultation.
Terms that will come up in every conversation about anti-money laundering over the next three years.
Body envisaged in the Spanish draft bill to bring together financial intelligence, supervision, inspection and sanctioning powers in anti-money laundering matters.
Spain’s financial intelligence unit and current supervisor. Its functions are being merged into the new authority.
Directly applicable EU anti-money laundering regulation that harmonizes the obligations of obliged entities across the Union. It applies from July 10, 2027.
Directive governing the mechanisms Member States must put in place: supervision, registers, cooperation and access to information. This is what Spain is transposing.
EU body created by Regulation (EU) 2024/1620, with direct supervision of certain entities and coordination of the rest.
A natural or legal person on which the law imposes due diligence, record keeping, suspicious activity reporting and internal control.
Document that identifies and assesses the money laundering risks specific to the business, and against which the whole AML/CFT system is calibrated.
A measure that prevents the funds in an account from being used while their origin or destination is investigated. The draft bill grants it to the new authority.
Whoever owns or effectively controls a client that is a legal person, directly or through a chain of shareholdings.
ANIFI is the National Financial Integrity Authority (Autoridad Nacional de Integridad Financiera), the body that the draft Bill on comprehensive measures for the prevention of money laundering, approved by the Council of Ministers on July 28, 2026, plans to create. It brings together financial intelligence, supervision, inspection and sanctioning powers.
It is set up as an independent body and is built on the structure of the FROB, which will no longer act as the bank resolution authority.
As a separate body, yes: it is merged into the new authority. But its functions do not disappear. The financial intelligence unit, the analysis of reports and supervision continue to exist, now within a broader body that also takes on powers currently held by the Treasury and the Ministry.
For an obliged entity, the practical effect is that it will have a single point of contact where it used to have several.
There is no fixed date yet, because the text is still going through the legislative process: the public hearing and consultation remains open until September 30, 2026, and after that comes the parliamentary process.
What does have a date is the underlying obligation: Regulation (EU) 2024/1624 applies from July 10, 2027, regardless of the status of the Spanish law. That is the timeline that should drive your preparation.
It is one of the new features of the draft bill: powers to suspend transactions and block accounts. Until now, the system’s response was essentially informational (the transaction was reported and then everyone waited), with no power of direct intervention by the supervisor.
For entities, this turns the technical capability to stop a transaction in progress into an operational requirement, not just a provision in the manual.
Not by itself. The substantive obligations come from Regulation (EU) 2024/1624, which is directly applicable: due diligence, beneficial ownership, record keeping, reporting and internal control. What changes with ANIFI is who supervises, with what resources and with what consequences.
In other words: the exam is the same, but the examiner has more time and more information.
The EU package extends the list to crypto-asset service providers, crowdfunding platforms, high-value goods dealers, investment migration operators and, with a separate deadline, professional football clubs and football agents.
If your business is coming into scope for the first time, check the full list on our obliged entities page and the EU regime on our AMLR page.
The draft bill’s approach is for it to be funded through fees paid by supervised entities, including gambling operators. It is a common model among financial supervisors and has a practical implication: an authority with its own stable funding has more inspection capacity than one that depends on the ordinary budget.
It is worth following this point during the legislative process, because it determines the real reach of the supervision to be expected.
ANIFI will be Spain’s counterpart to the AMLA, the EU authority created by Regulation (EU) 2024/1620, which will directly supervise certain high-risk cross-border entities and coordinate the other national supervisors.
For groups present in several Member States, this two-tier structure matters when deciding where to centralize the compliance function.
Yes. The Ministry of Economy’s public hearing and consultation accepts submissions until September 30, 2026, sent to the mailbox set up for that purpose. It is the formal channel for a sector to state its position on the scope, the thresholds or the applicable regime.
For sectors debating whether or not they fall within scope, or on what terms, it is a window that will not come again.
Three things, in this order. First, check whether the EU package changes your scope. Second, review whether your manual and your risk self-assessment describe the entity you are today, not the one you were five years ago. Third, test in practice the procedures that until now have only existed on paper.
None of this depends on the Spanish law being published, and everything you do now will still be useful later.
Everything stated on this page comes from the published EU legislative package or from official Spanish documents on the bill still going through the legislative process. These are the primary links.
Entry for the EU anti-money laundering regulation in the Spanish Official State Gazette (BOE), with access to the PDF of the original publication. It is the regulation that brings football within the scope of obliged entities.
boe.es · DOUE-L-2024-80912 BOEThe mechanisms Member States must put in place: supervision, registers and cooperation. It is the piece Spain must transpose.
boe.es · DOUE-L-2024-80913 BOEEstablishment of the EU Anti-Money Laundering Authority, with which the Spanish supervisor will coordinate.
boe.es · DOUE-L-2024-80910 Ministry of EconomyOfficial page for the public hearing and consultation on the Spanish reform that creates ANIFI and brings in the new obliged entities. Submissions until September 30, 2026.
portal.mineco.gob.es · public consultation La MoncloaOfficial summary of the decision approving at first reading the draft bill for a comprehensive reform of anti-money laundering rules.
lamoncloa.gob.es · Council of Ministers BOEConsolidated text of the Spanish law still in force, which the reform now going through the legislative process is set to replace.
boe.es · BOE-A-2010-6737Regulatory content ages quickly, and an outdated guide wastes the time of anyone who follows it. That is why we publish who maintains it and with what method.
Tell us what your entity does and what AML/CFT system you have in place today, and we will tell you what the new framework changes for you and where it makes sense to start.
For fifteen years, anti-money laundering in Spain has been built on a division of roles that is now considered exhausted: SEPBLAC received the information and supervised, sectoral supervisors watched their own areas, and sanctioning powers lay with the Ministry. The result was a system with good information and little capacity to react. ANIFI is being created to close that loop.
It is not an isolated initiative. In May 2024 the European Union adopted a complete package: Regulation (EU) 2024/1624, which harmonizes the obligations of obliged entities in a directly applicable regulation; Directive (EU) 2024/1640, which sets out the mechanisms each Member State must put in place; and Regulation (EU) 2024/1620, which creates the EU authority. Spain must transpose the directive and adapt its institutional architecture, and that is exactly the purpose of the draft bill approved in July 2026.
Bringing powers together would not change much on its own. What changes the system is the power to intervene: the possibility of suspending a specific transaction and of blocking accounts. Until now, an entity that detected a suspicious transaction reported it and, except in specific cases set out in the law, the transaction went ahead. With an authority able to intervene, the quality and speed of internal detection stop being a matter of formal compliance and become an operational matter with immediate consequences.
Much of the industry is treating the reform as a change of names. It is not. The substantive obligations come from the EU regulation and are more demanding than the current ones on due diligence, beneficial ownership and internal control; the new body is simply the one that will check that they are met, with more resources and its own funding. Preparing for the change of supervisor without reviewing the substance of the system is preparing for the wrong thing.
The draft bill is under public consultation until September 30, 2026, which opens two parallel paths. The first is to take part: for sectors debating their own scope, their thresholds or their transitional regime, it is the only real window of influence. The second is to start the work that does not depend on the final text: updating the risk self-assessment, checking that the manual describes the real entity, documenting training and testing that procedures work. That work will be fully useful, whatever the final terms of the law.
Key legislation, linked to the official text:
Legislation and links reviewed in .