Reporting obligations · SEPBLAC

Suspicious transaction reporting to SEPBLAC

When a transaction raises suspicion, Law 10/2010 requires you to examine it and, if there are indications of money laundering, to report it to SEPBLAC without delay, and without alerting the customer. We help you set up your detection, special examination and reporting (Form F19) workflow so that your entity complies with confidence.

Art. 17 · Special examination Art. 18 · Suspicious transaction reports Art. 24 · Non-disclosure Form F19

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1 Overview

What suspicious transaction reporting is

It is the obligation to inform SEPBLAC, on your own initiative, of any fact or transaction, even a mere attempt, where there is indication or certainty that it is related to money laundering, its predicate offenses or terrorist financing. It is the core of the reporting obligations of every obliged entity.

It is not an automatic report: the report is always preceded by a special examination of the transaction. If that analysis rules out the suspicion, there is nothing to report; if it confirms it, the report is made without delay.

“Obliged entities shall report to SEPBLAC, on their own initiative, any fact or transaction, even a mere attempt, in respect of which there is indication or certainty that it is related to money laundering or terrorist financing.” Principle set out in Article 18 of Law 10/2010

The person responsible for channeling these reports is the SEPBLAC representative, within the entity’s internal control system.

2 The process

From the first sign of suspicion to the report: how it works

Suspicious transaction reporting is not an isolated act but the end of a structured process. These are the four phases that should be clearly defined in your AML/CFT manual.

01

Detection

A complex or unusual transaction, or one with no apparent economic purpose, triggers an alert.

02

Special examination

The transaction is analyzed in a structured way (Art. 17) to confirm or rule out the suspicion.

03

Decision

If there is indication or certainty, a report is due; if the suspicion is ruled out, this is documented and the file is closed.

04

F19 report

The suspicious transaction report is sent to SEPBLAC without delay (Form F19).

Art. 17 Law 10/2010 The special examination requires you to look closely at every transaction or pattern that is complex, unusual or without any apparent economic or lawful purpose, or that shows signs of a sham or fraud. The manual must specify how this duty is met, with a list of risk transactions, its periodic review and suitable IT tools.

Art. 18 Law 10/2010 After that examination, if there is indication or certainty, the transaction is reported to SEPBLAC. The law also provides for the duty to refrain from executing transactions (Art. 19) in certain cases and for monthly systematic reporting (Art. 20) by certain categories of obliged entities.

3 Red flags

What makes a transaction “suspicious”

The law does not give a closed list: it refers to transactions that are complex, unusual or without any apparent economic or lawful purpose, or that show signs of a sham or fraud. These are patterns that, after the special examination, often heighten suspicion.

No economic rationale. Transactions with no apparent professional, economic or business justification.

Mismatch. Amounts that do not fit the customer’s activity, volume or history.

Structuring. Split or repeated transactions that appear designed to avoid thresholds or controls.

Customer opacity. Reluctance to provide identification, to justify the source of funds or to clarify who the beneficial owner is.

Risk connections. Links to high-risk jurisdictions or unnecessarily complex structures.

Sham or fraud. Signs that the transaction conceals a purpose other than the one stated.

Each entity must turn these red flags into its own list of risk transactions, tailored to its sector, geographic scope and volume, and review it periodically.

4 Non-disclosure

The golden rule: do not alert the customer

Once a transaction is examined or reported, a strict prohibition applies. This is one of the areas where entities most often make serious mistakes.

Prohibition of disclosure (Art. 24)

You may not tell the customer or third parties that a report to SEPBLAC has been or will be made, or that a transaction is undergoing a special examination. Disclosing this (known as tipping-off) can frustrate the investigation and constitute an infringement.

Art. 23 Law 10/2010 As a counterweight, reports made in good faith are protected: they do not breach confidentiality restrictions and do not give rise to liability for the obliged entity, its managers or its employees.

Be clear about which information is covered by the duty of non-disclosure: information reported in a suspicious transaction report (Art. 18), systematic reporting (Art. 20), information provided under the duty to cooperate (Art. 21) and any information that is or may be the subject of a special examination.

5 Support

How we help

We support your entity so that its detection and reporting workflow actually works and stands up to a supervisory inspection.

Detection and special examination

We design the list of risk transactions and the special examination procedure (Art. 17), tailored to your business.

Reporting to SEPBLAC

We help you prepare and submit the suspicious transaction report (Form F19) with the right content and documentation.

Non-disclosure protocol

We put confidentiality safeguards in place to prevent tipping-off and train your team to apply them.

Do you need to report a transaction to SEPBLAC?

We guide you through the special examination, the suspicious transaction report and the non-disclosure safeguards, step by step.

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? Common questions

Suspicious transaction reporting: common questions

What is a suspicious transaction report?

It is the report that an obliged entity makes to SEPBLAC, on its own initiative, when, after the special examination, there is indication or certainty that a transaction is related to money laundering or terrorist financing (Article 18 of Law 10/2010). It covers even a mere attempt.

Do I have to report every unusual transaction?

Not directly. First, a special examination is carried out (Art. 17). If that analysis rules out the suspicion, there is nothing to report; documenting the examination is enough. You only report when there is indication or certainty.

Which form is used to report?

Suspicious transaction reports are made to SEPBLAC using Form F19 (F19-1 structure), as a general rule on a physical medium, and without delay once the suspicion is confirmed.

Can I tell the customer?

No. Article 24 prohibits disclosing to the customer or to third parties that a report has been made or will be made, or that an examination is under way. This is known as the prohibition of disclosure, or the tipping-off prohibition.

Can I face consequences for reporting in good faith?

No. Article 23 provides an exemption from liability: a report made in good faith does not breach confidentiality restrictions and does not give rise to liability for the obliged entity or for its managers or employees.

How does it differ from systematic reporting?

A suspicious transaction report (Art. 18) is made when there is suspicion after the examination. Systematic reporting (Art. 20) is a monthly report of certain transactions that certain categories of obliged entities must send to SEPBLAC, whether or not there is any suspicion.

Who makes the report within the entity?

The channel to SEPBLAC is managed by the SEPBLAC representative, within the internal control system (manual, procedures and, where applicable, the internal control body).

What if the transaction has to be stopped?

In certain cases, the duty to refrain from executing transactions applies (Art. 19): the obliged entity refrains from executing the transaction before reporting it. Your manual should set out when and how to apply it.

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Suspicious transaction reporting in anti-money laundering compliance

Suspicious transaction reporting is the core of the reporting obligations that Law 10/2010 imposes on every obliged entity. Its purpose is to pass on to SEPBLAC the transactions that, after rigorous analysis, show indications of a link to money laundering or terrorist financing.

Special examination (Art. 17)

The starting point is the special examination: the duty to look closely at every transaction or pattern of behavior that is complex, unusual or without any apparent economic or lawful purpose, or that shows signs of a sham or fraud. The internal control manual (Art. 26) must specify how this duty is met, with a list of risk transactions, its periodic review and tools suited to the type of business.

Suspicious transaction reporting (Art. 18)

When the examination confirms indication or certainty, the transaction (including a mere attempt) is reported to SEPBLAC on your own initiative and without delay, as a general rule using Form F19. If the examination rules out the suspicion, no report is due, but it is advisable to document the analysis carried out.

Refraining and systematic reporting (Arts. 19 and 20)

Alongside suspicious transaction reporting, the law provides for the duty to refrain from executing the transaction in certain cases (Art. 19) and for monthly systematic reporting of certain transactions by certain categories of obliged entities (Art. 20), under the implementing regulation (Royal Decree 304/2014).

Prohibition of disclosure and exemption from liability (Arts. 24 and 23)

The obliged entity may not disclose to the customer or to third parties that a transaction has been or will be reported, or that an examination is under way (Art. 24). In return, reporting in good faith is protected and does not give rise to liability (Art. 23). A well-designed system balances both duties and protects the entity in an inspection.

Law 10/2010 Art. 17 · Special examination Art. 18 · Suspicious transactions Art. 19 · Refraining Art. 20 · Systematic reporting Art. 24 · Non-disclosure Form F19 SEPBLAC

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