Risk and manual
Risk assessment and manual
"It checks that the risk assessment is up to date and that the AML/CFT manual, which must be available to it, reflects the internal control measures actually in place."
SEPBLAC Inspection: What It Involves, What It Reviews and How to Prepare
We help you anticipate and respond to a SEPBLAC inspection: handling requests for information, reviewing your manual and internal controls, managing the case file and protecting you against the penalty regime of Law 10/2010, with your documentation ready and the right strategy.
Free consultation
We reply within 24 h
- Minimum fine, very serious infringement
- €150,000
- Fine for a minor infringement
- Up to €60,000
- Supervision and inspection
- Art. 47
- Key legislation
- Law 10/2010
Services
How we support you through a SEPBLAC inspection
Six building blocks to prepare for, handle and close a SEPBLAC inspection, from a preventive review of your system to responding to requests for information and managing the penalty regime.
Preparation
Inspection preparation and mock inspection
We review your AML/CFT system the way SEPBLAC would and detect gaps before the supervisor does: risk assessment, manual, customer files and reporting.
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Mock inspectionExternal reviewGapsLaw 10/2010
Requests
Responding to SEPBLAC requests for information
We help you answer SEPBLAC requests for information on time and in the proper form, preparing the documentation required and the strongest possible response.
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RequestDeadlineDocumentation
Manual
Review of the manual and internal controls
We update your AML/CFT manual and internal control measures so that they are available to SEPBLAC and withstand its review.
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AML manualInternal control
Governance
SEPBLAC representative and internal control body
We strengthen the role of the SEPBLAC representative and the internal control body, both key to dealing with the supervisor during the inspection.
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RepresentativeOCI
Penalties
Penalty regime and defense
We analyze the scope of potential infringements and build the defense in sanctioning proceedings, including how the penalty is graded and any mitigating factors.
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InfringementsDefense
Remediation
Remediation and corrective measures
We implement the corrective measures required by SEPBLAC after the inspection and bring your AML/CFT system up to date.
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Corrective measuresAction plan
What it reviews
What SEPBLAC looks at
The supervisor does not just look at the paperwork: it checks that your AML/CFT system actually works, from the risk assessment and the manual to transaction reporting and training.
Due diligence
Due diligence and KYC
"It checks customer files: identification, beneficial ownership and the application of standard and enhanced measures according to risk."
Reporting
Transaction reporting
"It verifies suspicious transaction reports and systematic reporting: whether transactions were given a special examination and whether they were reported to SEPBLAC when required."
Governance
OCI, representative and training
"It examines the internal control body, the SEPBLAC representative, the training plan and the annual external review."
Why it matters
Why is a SEPBLAC inspection critical?
An inspection can lead to recommendations, requirements to take corrective measures or sanctioning proceedings. Obstructing the inspection and serious breaches can result in very high fines.
The most common mistake: having a flawless manual that is not applied. SEPBLAC compares the paperwork with actual day-to-day operations, and the gap between the two is what gets penalized.
Cooperating is not optional: you must provide the documentation requested. Resisting or obstructing the inspection, once a formal request has been made, is a very serious infringement.
Penalties reach managers: in addition to the entity, liability can extend to directors and senior managers, with fines and disqualification.
Art. 56 Law 10/2010
Up to €10 million
For very serious infringements, the fine can reach the highest of several limits, up to €10 million.
Reprimand
Publication
Penalties can include a public reprimand, with reputational impact for the entity.
Authorized entities
Revocation
For entities that require authorization to operate, the penalty can extend to revocation of the authorization.
Have you received a request for information from SEPBLAC?
Whether you want to prepare preventively or already have a request on your desk, it pays to review your system, organize the documentation and plan your response carefully before the case moves forward.
Frequently asked questions
SEPBLAC inspection: common questions
What is SEPBLAC and what inspection powers does it have?
SEPBLAC (Executive Service of the Commission for the Prevention of Money Laundering and Monetary Offenses) is Spain’s financial intelligence unit and its AML/CFT supervisor. Under Article 47 of Law 10/2010, it supervises and inspects compliance with the obligations of obliged entities.
What does a SEPBLAC inspection involve?
It can be carried out remotely, through requests for documents and information, or through on-site visits. SEPBLAC analyzes your AML/CFT system, makes recommendations and can propose requirements to take corrective measures.
What documentation can it request?
Anything relevant to assess compliance, for example:
- AML/CFT manual and risk assessment.
- Due diligence and beneficial ownership files.
- Suspicious transaction reports and systematic reporting.
- Training plan and external review.
Am I required to cooperate?
Yes. Obliged entities must provide the documentation and information that SEPBLAC requests from them. Resisting or obstructing the inspection, where there is an express written request, is a very serious infringement.
What happens after the inspection?
Depending on the outcome, SEPBLAC can issue recommendations, propose to the Standing Committee requirements to take corrective measures or, in the event of significant breaches, open the way to sanctioning proceedings.
What infringements are there?
Law 10/2010 classifies infringements as minor, serious and very serious (Articles 50–53), depending on the obligation breached and how serious the breach is.
What penalties can be imposed?
Fines (which, for very serious infringements, can reach the highest of several limits, up to €10 million), private or public reprimand and, for authorized entities, possible revocation of the authorization, in addition to the liability of directors and senior managers.
How should you prepare for an inspection?
By keeping your system alive: an up-to-date risk assessment, a manual that is genuinely applied, organized files, reporting up to date, documented training and an external review. A mock inspection helps you detect gaps in time.
People also ask
SEPBLAC: manual, advance notice, penalties and limitation periods
Do you have to send the AML manual to SEPBLAC?
Not as a general rule. The AML/CFT manual is not submitted, but it must be kept up to date and available to SEPBLAC for the exercise of its supervisory and inspection functions.
Does SEPBLAC give notice before an inspection?
The inspection usually begins with a request for information that specifies the documentation to be provided and the deadline. It is best to have your system ready at all times, because the first contact is already part of the supervisory action.
Who imposes the penalties?
SEPBLAC investigates, and the Commission for the Prevention of Money Laundering and Monetary Offenses processes the case and makes a proposal; the penalty is imposed by the competent bodies of the Ministry or, in the most serious cases, by the Council of Ministers, depending on the seriousness of the infringement.
Are directors and senior managers liable?
Yes. Law 10/2010 provides for the liability of directors and senior managers (Article 54), who can be penalized in addition to the entity, with fines and even disqualification in the most serious cases.
When do infringements become time-barred?
Law 10/2010 regulates the limitation periods for infringements and penalties (Article 60), with different periods depending on their seriousness. How the periods are calculated and interrupted is key to the defense in sanctioning proceedings.
Is a public reprimand always published?
Not necessarily. Publication of a public reprimand can be delayed or handled differently where it could harm an ongoing investigation or endanger the stability of financial markets.
Infringements and penalties
Penalty regime under Law 10/2010: comparison
The outcome of an inspection depends on how serious the breach is. We help you assess its scope and build the best strategy in each scenario.
What determines the scope (and cost) of the matter
The effort depends on when you act: preparing preventively is not the same as responding to a request for information or defending yourself in sanctioning proceedings.
- Timing
- Preventive preparation, response to a request or defense in sanctioning proceedings.
- Seriousness
- Type of potential infringement: minor, serious or very serious.
- System
- State of the manual, the files and the reporting.
- Remediation
- Corrective measures to implement after the inspection.
How we handle the matter
We start from a realistic diagnosis of your system, organize the documentation and plan the response or the defense with the strongest strategy at each stage.
- Diagnosis of the system and of the documentation available.
- Response to the request or defense strategy.
- Implementation of corrective measures and follow-up.
| Infringement | Minor | Serious | Very serious |
|---|---|---|---|
| What it covers | Less significant breaches | Breaches of significant obligations | Obstruction, deliberate failure to report, etc. |
| Fine (indicative) | Up to €60,000 | From €60,001 (with upper limits) | From €150,000 up to €10 million |
| Other penalties | Private reprimand | Private or public reprimand | Public reprimand; possible revocation |
| Reaches managers | Exceptionally | Yes | Yes (including disqualification) |
| Legal basis | Arts. 53 and 58 | Arts. 52 and 57 | Arts. 51 and 56 |
Indicative table. The exact amounts and limits follow from Articles 56–59 of Law 10/2010 and from how penalties are graded; how each specific conduct fits must be analyzed case by case.
Practical guide
How to handle a SEPBLAC inspection: practical guide
An inspection is not won by improvising: it is won by keeping your system alive, your documentation organized and giving a measured response to each request. Prior preparation makes the difference between a recommendation and sanctioning proceedings.
Keep your system alive
SEPBLAC compares the paperwork with actual operations. An up-to-date risk assessment, a manual that is applied, organized files and reporting up to date are the best defense before the request arrives.
Respond with a clear head
Each request is answered on time, with the exact documentation requested and without improvising. Cooperation is mandatory; obstruction makes things worse.
Remediate and document
If there are recommendations or requirements to take corrective measures, they are implemented and a record is kept. Diligent remediation counts in your favor in any proceedings.
SEPBLAC inspection checklist in 10 steps
- Risk assessment: check that it is up to date and documented.
- Manual: verify that it reflects the internal control measures actually in place and is available to SEPBLAC.
- Files: organize due diligence, beneficial ownership and enhanced measures.
- Reporting: review special examinations, suspicious transaction reports and systematic reporting.
- Governance: SEPBLAC representative and internal control body up and running.
- Training: document the annual plan and employee participation.
- External review: have the annual external review report on file.
- Request: identify the deadline and the exact documentation requested.
- Response: answer on time and in the proper form, with precise documentation.
- Remediation: implement the corrective measures and keep a record.
If you want to prepare for an inspection or already have a request, see our anti-money laundering (AML/CFT) area or our external review / AML audit page.
SEPBLAC inspections in practice
From request to remediation
A SEPBLAC inspection should not be faced blind: you need to prepare, respond to requests, defend yourself if sanctioning proceedings follow and remediate the issues identified. Here is a visual overview of how it works in practice.
1) PreparePrepare: a living system
The starting point is not the inspection, but having your system working and documented so that it withstands review.
- Risk assessment and manual
- Files and reporting
- Training and external review
2) RespondRespond: the request
Each request is answered on time and in the proper form, with the exact documentation requested and a solid response.
- Deadline and scope
- Precise documentation
- Orderly dealings with the supervisor
3) DefendDefend: the sanctioning proceedings
If proceedings are opened, the defense is built: scope of the infringement, grading, mitigating factors and limitation periods.
- Legal characterization of the conduct
- Grading and mitigating factors
- Written submissions and appeals
4) RemediateRemediate: corrective measures
SEPBLAC’s recommendations and requirements translate into specific corrective measures, implemented and documented. Diligent remediation counts in the entity’s favor.
Tip: documenting remediation with dates and owners shows the supervisor your commitment to compliance.
Quick decisionPractical map: which stage are you at?
No request yet
Preventive review and mock inspection to detect gaps.
You have a request
A timely response with the exact documentation requested.
Sanctioning proceedings are open
Defense strategy: written submissions, grading and remediation.
SEPBLAC inspection playbook
The inspection, stage by stage
Preparation
Preventive review of the AML/CFT system and detection of gaps before any request.
Diagnostic report and improvement plan.
Request for information
SEPBLAC requests documents and information, specifying what must be provided and by when.
Acknowledgment of the request and response file.
Supervisor’s analysis
SEPBLAC assesses the system and can make recommendations or propose requirements to take corrective measures.
Recommendations and, where applicable, requirements.
Penalty regime
In the event of significant breaches, sanctioning proceedings may be opened and conducted.
Written submissions, evidence and defense.
Remediation
Implementation of the corrective measures required and strengthening of the AML/CFT system.
Remediation log with dates and owners.
Common mistakes with SEPBLAC
Spot them before they make the case worse.
- Having a flawless manual that is not applied in actual operations.
- Answering requests late or incompletely.
- Resisting or obstructing the inspection, which is a very serious infringement.
- Not documenting the special examination of transactions or the reports to SEPBLAC.
- Ignoring recommendations and failing to implement corrective measures.
Working glossary
Key concepts in a SEPBLAC inspection
If you are facing a SEPBLAC inspection, these terms appear in the requests and in the case file. Understanding them helps you respond with sound judgment and manage the risk of penalties.
SEPBLACBasics
Executive Service
Spain’s financial intelligence unit and AML/CFT supervisor, which supervises and inspects compliance with Law 10/2010.
Article 47 of Law 10/2010.
CPBCIMBody
Prevention Commission
Commission for the Prevention of Money Laundering and Monetary Offenses, the body on which SEPBLAC and sanctioning activity depend.
Chapter VII of Law 10/2010.
RequestProcedure
Request for information
A SEPBLAC request for documents and information, specifying what must be provided and by when. Responding to it is mandatory.
Duty to cooperate (Art. 21).
ManualControl
AML/CFT manual
Document setting out the internal control measures; it is not submitted, but it must be available to SEPBLAC for supervision and inspection.
Permanently available to the supervisor.
ReportingInformation
Suspicious transaction report (STR)
Report to SEPBLAC of transactions showing indications of money laundering or terrorist financing, alongside systematic reporting.
Arts. 18 and 20 of Law 10/2010.
External reviewReview
External expert report
Independent annual review of the internal control measures, which SEPBLAC usually examines during the inspection.
Internal control obligation.
InfringementSanctions
Types of infringement
Law 10/2010 classifies infringements as minor, serious and very serious, each with different penalties.
Arts. 50–53 and 56–58.
Corrective measuresRemediation
Requirement to remedy
Measures that SEPBLAC or the Standing Committee can require to correct the deficiencies detected in the inspection.
Failure to comply may be penalized.
ReprimandPenalty
Public reprimand
A penalty that can accompany a fine, with reputational impact; its publication can be delayed in certain cases.
Provided for in the penalty regime.
Contact
Book a call
Tell us about your situation with SEPBLAC and we will help you prepare, respond to requests for information and manage the risk of penalties with the right documentation.
Legal framework for SEPBLAC inspections: Law 10/2010 and the penalty regime
SEPBLAC supervises and inspects compliance by obliged entities with their obligations under Article 47 of Law 10/2010 of April 28 on the prevention of money laundering and terrorist financing, implemented by Royal Decree 304/2014. As a support body of the Commission for the Prevention of Money Laundering and Monetary Offenses, it also makes recommendations and proposes requirements.
Cooperation and documentation
Obliged entities must provide the documentation and information that the Commission or its support bodies, including SEPBLAC, request from them, and the request must specify the documentation to be provided. The AML/CFT manual is not submitted, but it must be kept up to date and available to SEPBLAC for its supervisory and inspection functions.
Penalty regime
Chapter VIII of Law 10/2010 (Articles 50–60) regulates infringements (minor, serious and very serious) and the corresponding penalties. For very serious infringements, the fine has a minimum of €150,000 and a maximum equal to the highest of several figures (10% of total annual turnover, twice the economic value of the transaction, five times the profits derived from the infringement, or €10,000,000, following the reform by Royal Decree-law 11/2018), and may be accompanied by a public reprimand and, for authorized entities, revocation. Resisting or obstructing the inspection is a very serious infringement.
Liability and limitation periods
Liability can extend to directors and senior managers (Article 54), and the Law regulates how penalties are graded (Article 59) and the limitation periods for infringements and penalties (Article 60), key aspects of the defense in sanctioning proceedings.
The EU AML package
The new EU framework (Regulation (EU) 2024/1624 — AMLR — and the AMLA authority) will strengthen AML supervision across the EU, applying from July 10, 2027, so it is advisable to strengthen your system now with that horizon in mind.
AML/CFT services
Related areas
Resources and blog
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
- Regulation (EU) 2024/1624 of May 31, 2024 on the prevention of the use of the financial system for the purposes of money laundering or terrorist financingEUR-Lex · Official Journal of the EU
Legislation and links reviewed in .