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Money Laundering

This area has two sides and they are worth separating. One is preventive: Spanish Law 10/2010 imposes duties on banks, estate agents, notaries, professional firms and a good many businesses that do not know they are covered. The other is criminal: defending someone investigated under article 301 of the Criminal Code, often over a transaction they did not realise could be read that way.

Euro banknotes fanned out in close-up

What we do

  • We determine whether your activity is a regulated entity under Law 10/2010 — the first question, and not always obvious.
  • We draft the prevention manual, the client acceptance policy and the customer due diligence procedures.
  • We train staff and prepare the annual external review where the rules require one.
  • We assist with SEPBLAC requests and inspections and with any resulting sanction proceedings.
  • We take on criminal defence in money laundering proceedings, from the investigation stage.
  • We act where a bank freezes funds or closes an account under its internal prevention rules.

What people usually bring us

  • A bank freezing a transfer and asking you to evidence the origin of the funds.
  • A business that has just discovered it is a regulated entity and has nothing in place.
  • A SEPBLAC request with a deadline to answer.
  • A summons as a person under investigation in criminal proceedings over a specific transaction.

Best said plainly: this firm works in compliance and in defence. It does not design structures or transactions to conceal the origin of funds, and does not accept that instruction. If what you need is to evidence where your money comes from, before a bank or before a court, there we can help — and the sooner the paperwork is put in order, the better.

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