What is a Suspicious Transaction in Spain?

Introduction

In Spain, financial institutions and other obligated entities are required by law to report any suspicious transactions to the Spanish Financial Intelligence Unit (FIU), known as Sepblac. This reporting requirement is aimed at preventing money laundering and terrorist financing.

Definition of a Suspicious Transaction

A suspicious transaction is defined as an act or operation that, after a special review, shows indications or certainty of being related to:

• Money laundering
• Its predicate offenses
• Terrorism financing

The obligated entities must report these transactions without delay, following a structured process of special review.

Reporting Requirements

The report must contain specific information about the natural or legal persons involved in the transaction, including:

• Their activities
• The purpose of the transaction
• Any other relevant data

Additionally, the report must include details about the steps taken by the obligated entity to investigate the transaction and any other relevant data.

Submission Process

Suspicious transactions reports can be submitted:

Electronic Submission

• Via the CTL 2.3 software
• By credit institutions, savings banks, cooperative banks, and branches of foreign credit institutions
• Requires a digital certificate, valid for four years

Hard Copy Submission

• At Sepblac’s headquarters
• At the General Registry of the Bank of Spain
• For obligated entities that are not credit institutions

Submission Deadline

The submission deadline for suspicious transactions reports is immediate, meaning they must be submitted as soon as possible after the special review process is complete.