SEPBLAC is not disappearing: it is being merged into a new authority. The difference between those two statements matters far more than it seems, because it determines what you need to change in your AML/CFT system and what you can leave as it is. This page compares, function by function, who does what today and who will do it afterwards, and translates that change into the day-to-day operations of an obliged entity.
How it affects your entity
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The most common reading (“a new body is coming”) is inaccurate and leads entities to prepare for the wrong thing. What is actually happening is a reorganization: functions currently performed by three different players are being concentrated in a single one, which is also being built on an existing structure.
SEPBLAC is merged into the new authority. Its role as financial intelligence unit, the analysis of reports and its supervisory work all continue; they change hands and are combined with powers currently held by the Treasury and the Ministry.
No report will be left without a recipient, and no ongoing case will be left without an investigating officer.
Concentration and intensity. A single point of contact to report to, be supervised by and be sanctioned by; its own funding through fees; and the power to intervene directly in operations.
It is also being built by transforming the FROB (Spain’s bank restructuring fund), which gives it a structure from day one instead of having to create one.
This is the table to keep handy when someone in your organization asks: “Is someone else handling this now?” The answer is almost always yes, and it is almost always the same body.
| Function | Today | With ANIFI |
|---|---|---|
| Financial intelligence | SEPBLAC | ANIFI, with more resources and with access to supervisory information. |
| Receipt of reports | SEPBLAC | ANIFI. The formal recipient changes, not the obligation or its content. |
| Supervision and inspection | SEPBLAC and sectoral supervisors | ANIFI, with consistent criteria across sectors. |
| Sanction proposal | SEPBLAC | ANIFI, which also issues the decision. |
| Sanctioning decision | Ministry of Economy | ANIFI. The intermediate step that currently drags proceedings out disappears. |
| International financial sanctions | Treasury and Ministry | ANIFI, integrated with ordinary supervision. |
| Intervention in operations | Practically nonexistent | ANIFI, with time-limited powers to suspend and block. |
| Bank resolution | FROB | Bank of Spain and CNMV, each in its own sector. The FROB is transformed into ANIFI. |
| European liaison | Several channels | ANIFI as the single point of contact with the EU anti-money laundering authority. |
Table based on the draft bill submitted to public consultation and on the official information available. The final allocation may change during the parliamentary process.
Our recommendation is simple: do not prepare “for ANIFI”; use the change as an opportunity to review what has gone untouched for years. That is what a supervisor with more resources will find first.
We test your manual, your risk self-assessment, your procedures and your reporting history against what the EU framework will require and what a supervisor applying consistent criteria across sectors will look at.
The substantive obligations come from Regulation (EU) 2024/1624, not from the body. We align your system with the EU rules so you do not have to do the work twice when the Spanish law arrives.
Review of the detection procedure and of the actual content of what is reported. An abnormally low volume for the entity’s profile is the first signal any supervisor cross-checks.
The power to suspend transactions and block accounts requires the entity to be able to carry out such orders. We test and time that capability before it becomes mandatory.
Review of the appointment, duties and real availability of your representative before the new supervisor, and of how the internal control body actually works.
A mock inspection using the new supervisor’s expected criteria, and preparation of the documents that are requested first.
This distinction is the key to all preparation. The substantive obligations (due diligence, beneficial ownership, record keeping, reporting) come from the EU Regulation and are the same with SEPBLAC or with ANIFI. What changes is the institutional framework.
| Aspect | What your entity will notice |
|---|---|
| Recipient of reports | The receiving body changes. Your internal procedure must be updated, but the content and deadlines of the obligation do not change for this reason. |
| Frequency of supervision | A body with its own funding and a larger structure has more inspection capacity than the current one. Expect more supervisory activity, not less. |
| Length of proceedings | With investigation and decision concentrated in one body, sanctioning proceedings should move faster. |
| Consistency of criteria | A single supervisor for all sectors reduces differences in criteria between obliged entities in different businesses. |
| Operational demands | A new capability appears: being able to carry out suspension and blocking orders within days. |
| European liaison | Groups with a presence in several Member States will have a single point of contact with the EU authority. |
Assessment based on the institutional design set out in the draft bill. It is not a forecast of the actual intensity of supervision, which will depend on the resources allocated.
Five milestones between the adoption of the EU package and the moment the new authority becomes operational.
Regulation (EU) 2024/1624, Directive (EU) 2024/1640 and Regulation (EU) 2024/1620. Published in the Official Journal on June 19, 2024, according to SEPBLAC’s own note.
First reading of the text that creates ANIFI, merges SEPBLAC into it and transforms the FROB, giving the Bank of Spain and the CNMV executive resolution powers in their respective sectors.
Process open for submitting comments to the Ministry of Economy. It is the window for a sector to state its position on scope, thresholds or the applicable regime.
The AMLR applies generally, regardless of where the Spanish legislative process stands. This is the date that should drive any obliged entity’s preparation.
Once the law is passed, the new authority takes over its functions and begins inspecting. Ongoing cases and reports are not left in limbo: they change hands.
The risk of the handover does not lie in the administrative transition, which will sort itself out. It lies in what a supervisor with more resources finds when it looks more closely.
Preparing for the wrong change: putting the effort into updating the recipient’s name in the manual while the risk self-assessment is still the one from five years ago is the most common way to arrive poorly prepared.
Waiting for the Spanish law: the EU Regulation applies from July 2027 regardless of the national legislative process. Anyone who waits for the BOE will be late on the underlying obligation and rushed on the institutional one.
A history that is now read in full: with investigation and decision in the same body, an entity’s complete series of reports is easier to analyze. A pattern of under-reporting no longer goes unnoticed.
Sectors used to lenient supervisory criteria may find themselves applying the standard of more mature sectors, with no gradual transition.
An authority funded by fees has stable inspection capacity. Expect more supervisory activity on obliged entities that rarely receive it today.
The ability to carry out suspension and blocking orders is a new operational obligation that most entities have never tested.
We review your system against the criteria expected under the new framework and give you a report on what an inspection would find, ranked by severity and by the effort needed to fix it.
REGULATORY CONTROL CENTER · SUPERVISORY HANDOVER
The change of supervisor does not weigh the same on every obliged entity. This panel shows where it makes sense to start, based on each entity’s starting point.
An indicative reference to prioritize the work and size the project team.
They all stem from reading the reform as a change of acronym rather than a change in what is required.
Replacing “SEPBLAC” with “ANIFI” in the manual prepares nothing. What a supervisor with more resources finds first is an outdated risk self-assessment and the gap between the written procedure and actual operations.
The substantive obligations come from the EU Regulation, which applies from July 2027 without the need for national legislation. Waiting for the BOE means arriving late to what is already required.
A body built on an existing structure and with its own funding does not need years to start inspecting. The institutional transition does not suspend obligations.
With investigation and decision concentrated in one body, an entity’s complete series of reports is easier to analyze. It is worth knowing what that series says before someone else reads it.
The power to suspend transactions and block accounts is a new operational obligation. No entity has tested it, and testing it now is quick and cheap.
The process is still open, and it will shape the scope, thresholds and regime for several sectors. For some, it is the only real window of influence.
Three principles to direct the effort where it matters.
What will be checked is compliance with the EU framework. The name of the body that receives your reports is an administrative detail; the quality of the risk self-assessment is not.
Training with records, documented client acceptance decisions, and transaction analyses filed and retrievable. A supervisor with more time looks at more files.
A blocking protocol that nobody has ever executed is not a procedure. Testing it, timing it and keeping a record of the test is the difference between having one and believing you have one.
If you would like a prior review of your system, see our AML services or request a free consultation.
Pieces of the new institutional map that should not be confused with one another.
Body envisaged in the Spanish draft bill that brings together financial intelligence, supervision, inspection and sanctioning powers in anti-money laundering matters.
Spain’s current financial intelligence unit and supervisor. Its functions are being merged into the new authority.
Body on whose structure the new authority is being built, and which will stop performing bank resolution.
Body created by Regulation (EU) 2024/1620, with direct supervision of certain entities and coordination of the rest.
Directly applicable regulation that harmonizes the obligations of obliged entities. Applicable from July 10, 2027.
Directive on the mechanisms Member States must put in place: supervision, registers and cooperation. It is what Spain is transposing.
Body that receives and analyzes suspicious activity reports and disseminates intelligence to the competent authorities.
The power to decide proceedings and impose fines. It currently lies with the Ministry; the draft bill transfers it to the authority.
Funding model envisaged for the authority, paid by financial institutions and gambling operators.
As a separate body, yes: it is merged into the new authority. But its functions continue. The financial intelligence unit, the analysis of reports and supervisory work continue to exist within a broader body.
No report is left without a recipient and no ongoing case without an investigating officer: they change hands.
As regards content and deadlines, no: the obligation to report suspicious activity comes from the EU framework and does not change because of the institutional handover. What you will need to update, once the law comes into force, is the formal recipient in your internal procedure.
That said, it is worth reviewing the quality of what you report: a body with more resources analyzes complete series, not isolated reports.
That whoever inspects you is also whoever sanctions you. Today SEPBLAC proposes and the Ministry decides; the draft bill brings both together. That should mean faster sanctioning proceedings.
The second difference, and not a minor one, is the power to intervene in operations through suspensions and blocks, which practically does not exist today.
It is reasonable to expect so. An authority with a larger structure and its own funding through fees has stable inspection capacity, unlike a service that depends on the ordinary budget.
The effect will be most noticeable in sectors that rarely receive direct supervision today: professionals, real estate agencies and the sectors the EU package brings into scope for the first time.
On its own, none. The substantive obligations (due diligence, beneficial ownership, record keeping, reporting, internal control) come from Regulation (EU) 2024/1624, which applies from July 10, 2027, regardless of the Spanish law.
The only genuinely new requirement introduced by the draft bill is operational: being able to carry out suspension and blocking orders. We cover this on our page on ANIFI account freezing.
It is not advisable. The EU Regulation applies from July 2027 whatever the status of the Spanish legislative process, and the substantive work (updating the risk self-assessment, reviewing the manual, documenting training) does not depend on the final text.
That work will be fully useful, whatever form the law finally takes.
It is transformed. The new authority is being built on its structure, and the FROB will no longer be the bank resolution authority or manage public shareholdings. Those resolution functions pass to the Bank of Spain and the CNMV in their respective areas.
For an AML obliged entity this makes no substantive difference, but it explains why the new authority will have a structure from day one.
The Bank of Spain, the CNMV and the Directorate-General for Insurance and Pension Funds (DGSFP) keep their prudential and conduct supervision. What is concentrated in the new authority is specific anti-money laundering supervision.
The aim is consistency: the same breach should receive the same treatment regardless of the obliged entity’s sector.
ANIFI will be the single point of contact with the AMLA, 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.
There is no fixed date: the draft bill was approved at first reading on July 28, 2026, its public consultation is still open, and the parliamentary process comes after that.
The date that is firm is that of the EU Regulation, July 10, 2027, and it is the one that should drive any adaptation plan.
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.
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 SEPBLACNote from the Spanish supervisor on the three acts published in the Official Journal of the EU on June 19, 2024, covering the new obliged entities and the €10,000 cash limit.
sepblac.es · legislative package 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 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 when you last reviewed your AML/CFT system, and we will tell you what the handover really changes for you and where to start.
The way the reform has been presented (“a new authority is coming”) is inaccurate, and it is leading many entities to prepare for the wrong thing. What is happening is not the creation of an additional layer of supervision but a reorganization: functions currently performed by three different players are being concentrated in a single one, which is also being built on an existing structure.
Today, a suspicious transaction report follows a path with several hand-offs: the entity reports to SEPBLAC, which analyzes it; supervision is split between SEPBLAC itself and the sectoral supervisors; one body draws up the sanction proposal and the Ministry issues the decision. That path explains much of the length of proceedings. With ANIFI, the same matter stays within a single body from start to finish. The foreseeable consequence is not more lenient proceedings, but faster ones.
This is worth stressing, because it is where most effort is being wasted: the substantive obligations do not depend on the body. Due diligence, identification of beneficial ownership, record keeping, the duty to report and the duty to refrain come from Regulation (EU) 2024/1624, which is directly applicable and applies from July 10, 2027, regardless of where the Spanish legislative process stands. The examiner changes, not the exam.
Three things. First, whoever inspects also sanctions. Second, the authority will have its own funding through fees, which means stable inspection capacity: expect more supervisory activity, especially in sectors that rarely receive it today. And third, the only genuinely new obligation: the ability to carry out orders suspending transactions and blocking accounts within days, something practically no entity has ever tested.
The draft bill is under public consultation until September 30, 2026, which allows you to do two things at once. Take part, if the scope or the thresholds affect your sector, because it is the only real window of influence. And move forward with the work that does not depend on the final text: checking whether your manual describes the entity you are today, updating the risk self-assessment, documenting training and checking that written procedures work in practice. None of that will be wasted, whatever wording is finally approved.
Key legislation, linked to the official text:
Legislation and links reviewed in .