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Spain’s Anti-Money Laundering Efforts: Key Findings and Recommendations

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Supervisory Actions by SEPBLAC

SEPBLAC, the Spanish Public Agency for Liquidity and Financial Stability, has been actively working to combat money laundering. Here are some key findings related to its supervisory actions:

Lawyers

• In 2017 and 2018, SEPBLAC conducted assessments of 17 law firms involving around 2,934 lawyers in 2017 and 3,045 lawyers in 2018.
• The results showed that lawyers needed improvements in identifying customers and beneficial owners and analyzing suspicious transactions.

Trust and Company Service Providers (TCSPs)

• SEPBLAC inspected six TCSPs between 2014 and 2015, but the assessment team questioned whether separate inspections were necessary since many lawyers provide these services.
• The establishment of a registry and the presence of several TCSPs with appointed AML representatives may require separate inspections.

Real Estate Agents

• SEPBLAC conducted 39 inspections of real estate agents, resulting in:
  • Nine firms being sanctioned (fined and reprimanded)
  • A clear improvement in supervision intensity

Jewellers

• SEPBLAC conducted six inspections, resulting in sanctions totaling €360,000.
• Outreach activities also contributed to identifying new money laundering typologies in the sector.

Recommendations

The assessment team suggests:

Improve TCSP Supervision

• Separate inspections of TCSPs may be necessary due to the establishment of a registry and the presence of several TCSPs with appointed AML representatives.

Enhance Lawyer Supervision

• SEPBLAC should continue to improve its supervisory efforts, focusing on:
  • Customer identification
  • Beneficial ownership analysis
  • Suspicious transaction reporting