SEPBLAC Representative in Spain
The SEPBLAC representative is the person responsible for your entity's reporting obligations to SEPBLAC, Spain's Financial Intelligence Unit (Article 26 ter of Law 10/2010). We explain what the role is and what the law requires, and we provide technical support for the appointment (Form F22) and for day-to-day AML/CFT compliance.
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What is a SEPBLAC representative?
It is the person the obliged entity appoints as responsible for complying with its reporting obligations to SEPBLAC, in particular suspicious transaction reporting. The role is set out in Article 26 ter of Law 10/2010 and in Article 35 of its implementing regulation (Royal Decree 304/2014), and was introduced by Royal Decree-law 11/2018.
To perform this role, the representative has unrestricted access to all information held by the obliged entity. It should not be confused with the company's legal representative (although both roles can be held by the same person) or with the internal control body (OCI).
What the representative does
The role centers on the flow of information to the supervisor, with full access to the entity's data.
Channels reporting to SEPBLAC
They are the person responsible for the reporting obligations: they file suspicious transaction reports and respond to information requests from the Commission's Executive Service.
Has access to all information
They have unrestricted access to any information held by the obliged entity, so they can analyze and report.
Oversees the AML system
Where the entity is exempt from setting up an internal control body, the representative also takes on those functions.
Operates separately from internal audit
The AML bodies act with functional separation from the internal audit department, while coordinating with it.
Can you have an "outsourced" SEPBLAC representative?
It is worth distinguishing between who can be the representative under the law and what support a specialized law firm can provide.
The representative
- A natural person resident in Spain.
- Who holds a director or senior management position in the company.
- Appointed by the obliged entity's management body.
- For sole traders and individual professionals, the role falls on the business owner.
External support
- Advice on choosing and appointing the representative.
- Preparation of Form F22 and the supporting documents.
- Design and operation of the detection and reporting system.
- Training and ongoing support for compliance.
Important: the law requires the representative to hold a director or senior management position and to reside in Spain, so a third party outside the entity cannot act as "the representative" in the strict sense. What is entirely possible — and highly advisable — is to rely on a specialized law firm that supports the appointed representative and runs the AML/CFT system.
How the appointment works: Form F22
The appointment is notified to the Commission's Executive Service (SEPBLAC), which may raise reasoned observations.
Management body resolution
The management body resolves to appoint the representative, recorded in minutes or a certificate.
Form F22
The appointment proposal (Form F22) is completed and signed by a person who can evidence their position.
Documentation
Attach the documents evidencing the appointment by the management body and the signature of the appointed person.
Submission
The file is sent to the Commission's Executive Service, which may raise reasoned observations.
Key details to get right
- The minutes or certificate of the resolution is a private document: it does not need to be notarized.
- It must expressly state the appointment as "representante ante el SEPBLAC" (SEPBLAC representative).
- The proposal is usually accompanied by a description of the professional background of the appointed person.
- The law provides for the appointment of one person as representative, who must hold a director or senior management position.
We help you prepare the entire application file. See also our pages on suspicious transaction reporting and the overall AML/CFT framework in Spain.
How we help
We support the appointed representative and run the AML system so that compliance is real, not just on paper.
Appointment and Form F22
We advise you on who can be the representative and prepare Form F22 and all the appointment documents.
System and manual
We design the internal control manual and procedures (art. 26) and the workflow for detecting and reporting to SEPBLAC.
Ongoing support
We train your team, support the representative day to day and prepare the entity for information requests or inspections.
Need to appoint a SEPBLAC representative?
We advise you on the role, prepare Form F22 and support compliance with the reporting obligations.
SEPBLAC representative: common questions
What exactly is a SEPBLAC representative?
It is the person the obliged entity appoints as responsible for complying with its reporting obligations to SEPBLAC, as provided in Article 26 ter of Law 10/2010 and Article 35 of its implementing regulation. They have unrestricted access to the entity's information.
Who can be the SEPBLAC representative?
A person resident in Spain who holds a director or senior management position in the company, appointed by the management body. For sole traders and individual professionals, this role is performed by the business owner.
Can the representative be someone from outside the company?
Not in the strict sense: the law requires a director or senior management position and residence in Spain, so an external third party cannot act as "the representative". You can — and should — rely on a law firm that supports the appointed representative.
Is it the same as the legal representative?
No. They are different roles, although they can be held by the same person. The SEPBLAC representative is accountable for anti-money laundering reporting obligations.
What about the internal control body (OCI)?
They are different things. When the entity is exempt from setting up an OCI, its functions are performed by the representative. Both bodies operate with functional separation from internal audit.
How is the representative appointed?
Through the appointment proposal (Form F22) submitted to the Commission's Executive Service, together with the minutes or certificate of the management body and the documentation of the appointed person. SEPBLAC may raise observations.
Does the appointment have to be notarized?
No. The minutes or certificate of the resolution is a private document that does not need to be notarized, but it must expressly refer to the appointment as SEPBLAC representative.
What happens if I don't appoint a representative?
The appointment is an internal control obligation for obliged entities. Failing to comply is a deficiency in your AML system and may have consequences under the penalty regime of Law 10/2010.