1. Does Spain have a sanctions regime in place?

Yes, the Kingdom of Spain has a sanctions regime governed by the following legislation:

  • Money Laundering and Counter-Terrorism Act 10/2010 of 28 April 2010, (“Act 10/2010”) which implements Directive 2015/849 of the European Parliament and Council, of 20 May 2015, on the prevention of the use of the financial system for the purposes of money laundering or terrorist financing, amending Regulation (EU) No 648/2012 of the European Parliament and of the Council, and repealing Directive 2005/60/EC of the European Parliament and of the Council and Commission Directive 2006/70/EC.
  • Royal Decree 304/2014 of 5 May, adopting the regulation of the Act 10/2010 (“Royal Decree 304/2014)
  • Act 12/2003, of 21 May, on blocking the financing of terrorism (“Act 12/2003”)
  • Act 19/2003, of 4 July, on capital movements and economic transactions abroad legal regime (“Act 19/2003”)

2. Does Spain implement UN sanctions?

Yes it does.

3. Does Spain implement an autonomous sanctions regime?

No. The sanctions regime implemented in Spain mainly consists of implementing EU legislative measures. Act 10/2010, as noted above, implements EU Directive 2015/849. According to Article 96(1) of the Spanish Constitution, UNSC Decisions imposing sanctions will be part of Spanish Law once they have been published in the official journal (so-called Boletín Oficial del Estado or “BOE”).

4. What is the nature of the sanctions regime in Spain?

The infringement of the provisions set out in Act 10/2010 may give rise to administrative and criminal sanctions as follows:

  • administrative sanctions are established in Arts. 50 to 65 of Act 10/2010
  • criminal sanctions are established in Arts. 301 to 303 of the Spanish Criminal Code

5. Does Spain maintain a list of sanctioned individuals and entities?

Spain has not issued its own list as Act 10/2010 expressly refers to the EU and UN lists.

6. Are there any other lists related to sanctions in Spain?

The Spanish Ministry of Economy publishes a list of jurisdictions under monitoring due to their failure to implement efficient measures to control money laundering and terrorism financing;

7. Does Spain have a licensing or authorization system in place?

Yes. The General Directorate of the Treasury and Economic Policy through the Sub-Directorate General of Inspection and Control of Capital Movements is responsible for authorizing any exemptions to the above described sanctions. After filing the request, the Sub-Directorate may authorize the release of funds in frozen or blocked accounts within a maximum delay period of six months.

8. What are the consequences for a breach of sanctions in Spain?

The infringement of any EU restrictive measure is categorized as very serious infringement and gives rise to additional sanctions under Act 10/2010.

Fines on Companies

In addition to a public warning addressed to the infringer, the administration can impose fines between EUR150,000 and any of the following amounts: (i) 10% of the net assets of the company or person being sanctioned, (ii) double of the economic value of the given operation (iii) five times the amount of the benefits resulting from the infringement when such benefits could be established or (iv) EUR 10 million. Furthermore, the infringement can lead to the removal or suspension of any administrative authorization granted to operate in the market.

In the case of the company or person being sanctioned is a subsidiary of the parent company which have to establish consolidated financial accounts in accordance with article 22 of Directive 2013/34/UE, the maximum fine shall be calculated on the basis of the net assets or the type of revenue corresponding to the last available consolidated account approved by the management body of the parent company.

Fines on individuals

Penalties imposed directly on individuals may go from (i) fines in the range EUR60,000 to EUR 10 million or (iii) the prohibition to exercise any management task in the sanctioned company or in any entity/company subject to the Act 10/2010 for a maximum of ten years.

As mentioned above, certain infringements may also give rise to criminal penalties.

9. Where are the relevant regulators in Spain and what are their contact details?

The relevant regulator is La Comisión de Prevención del Blanqueo de Capitales e Infracciones Monetarias, (the Commission for the Prevention of Money Laundering and Finantial Infringements, within the Ministry of Economy Secretary of State, so-called the “SEPBLAC”) which is located in Madrid. La Comisión de Prevención del Blanqueo de Capitales e Infracciones Monetarias Calle de Alcalá 48 28014 Madrid Spain T: (+34) 913 38 88 08

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Crisanto Pérez-Abad


María Rodríguez Villegas Lawyer

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Paseo de la Castellana,

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