Financial Crime World

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Spain’s Financial Sanctions List: A Comprehensive Overview

In Spain, financial sanctions are governed by various legislation, primarily the Money Laundering and Counter-Terrorism Act 10/2010, which implements EU Directive 2015/849 on the prevention of the use of the financial system for the purposes of money laundering or terrorist financing. The Spanish government has also implemented UN sanctions through Royal Decree 304/2014.

Implementation of UN Sanctions

Spain does implement UN sanctions, with UNSC decisions imposing sanctions being part of Spanish law once published in the Official Journal (Boletín Oficial del Estado). This is stipulated by Article 96(1) of the Spanish Constitution.

Autonomous Sanctions Regime

Unlike some other countries, Spain does not have an autonomous sanctions regime. Instead, its sanctions regime primarily consists of implementing EU legislative measures. Act 10/2010, for instance, implements EU Directive 2015/849.

Sanctions Enforcement and Penalties

Infringements of the provisions set out in Act 10/2010 can result in administrative and criminal penalties. Administrative sanctions include:

  • Fines ranging from EUR150,000 to EUR10 million
  • Criminal sanctions can lead to imprisonment

Licensing and Authorization System

Spain has a licensing or authorization system in place for exemptions to sanctions. The General Directorate of the Treasury and Economic Policy’s Sub-Directorate General of Inspection and Control of Capital Movements is responsible for authorizing such exemptions.

Consequences of Breach

Breach of sanctions can result in serious consequences, including:

  • Fines
  • Public warnings
  • Removal or suspension of administrative authorizations

Regulators and Contact Information

The relevant regulator in Spain is the Commission for the Prevention of Money Laundering and Financial Infringements (SEPBLAC), which is located in Madrid.

Contact details: Commission for the Prevention of Money Laundering and Financial Infringements Calle de Alcalá 48 28014 Madrid, Spain Phone: (+34) 913 38 88 08

Disclaimer

The information contained on this site is intended as a guide only. While the information it contains is believed to be correct, it is not a substitute for appropriate legal advice. Eversheds Sutherland can take no responsibility for actions taken based on the information contained in this document.