The Anti-Money Laundering and Counter-Terrorist Financing (AML/CTF) department at Summons Lawyers has been consulted by Gabriel Vedrenne, a journalist specializing in the field from the website www.moneylaundering.com of ACAMS, regarding the decline in on-site inspections by SEPBLAC, as indicated by the publication of official data for 2022 by the Spanish anti-money laundering authority last July.
In this regard, our AML/CTF expert, Juan Berberian, expressed the opinion that while it is true SEPBLAC has significantly reduced on-site inspections recently, we believe this circumstance was initially driven by the pandemic and subsequently by the increase in so-called "thematic supervisions" - that is, requests for information from obliged entities on specific aspects of their AML/CTF frameworks - which lately focus on due diligence, training, internal controls, and compliance with international financial sanctions regimes.
It is important to clarify that these "thematic supervisions" represent a different form of oversight compared to "comprehensive inspections," which typically involve on-site visits to the premises of obligated entities to comprehensively evaluate their implemented AML/CTF frameworks.
This approach by SEPBLAC is grounded in a risk-based inspection system, which justifies supervisors' efforts focusing on those aspects that, based on their knowledge and data, are most relevant in the field.
At Summons Lawyers, we stand ready to assist obligated entities in developing and continuously improving their AML/CTF programs, as well as providing specialized training and support in response to regulatory requirements in this area.
