ANIFI — Spain’s new AML authority, and what it absorbs
Spain is proposing to fold SEPBLAC into a new independent authority — and to have obliged subjects pay for it directly, through a levy rather than the State budget. On 28 July 2026 the Council of Ministers approved, at first reading, a draft bill creating the Autoridad Nacional de Integridad Financiera (ANIFI). It unifies powers currently split between SEPBLAC and the Secretariat of the Commission for the Prevention of Money Laundering, and picks up functions no Spanish authority currently holds. This is an anteproyecto at first reading, now going to public consultation — the earliest stage in the process, and further from law than anything else on this site.
1. What actually changes
Spain’s AML architecture has been split in two for a long time, and the split is the thing being fixed. SEPBLAC — the Servicio Ejecutivo de la Comisión de Prevención del Blanqueo de Capitales e Infracciones Monetarias — operates as the financial intelligence unit and the supervisor that inspects obliged subjects. The Secretariat of the Commission sits separately and carries the policy and sanctioning machinery. An obliged subject deals with both, in different capacities, often on the same file.
The draft bill merges those competencies into a single independent administrative authority. That legal form matters more than it sounds: it is the same category Spain uses for bodies designed to sit outside the ordinary ministerial hierarchy, with their own governance and their own budget. The stated pairing behind the reform is institutional and substantive at once — build a specialised, independent authority, and align Spanish law with the 2024 EU anti-money-laundering package and with FATF standards.
| Function | Today | Under the draft bill |
|---|---|---|
| Financial intelligence unit | SEPBLAC | ANIFI |
| Supervision and inspection | SEPBLAC | |
| Sanctioning power | Commission / Secretariat | |
| International financial sanctions | Split | |
| Proliferation financing | No authority currently assigned |
That last row is the one to notice. The reform is not purely a merger — it also allocates supervision of financing of the proliferation of weapons of mass destruction, which the official account describes as a competence not previously assigned to any authority. For obliged subjects that have treated proliferation financing as a screening problem rather than a supervised obligation, that is a new supervisory relationship rather than a rebranding.
2. You will be paying for your own supervisor
The funding model is the part of this reform with a direct line to a compliance budget, and it is unusual enough to plan for. ANIFI is to have an autonomous and sustainable financing system that does not depend on the State’s General Budget. Two revenue sources are named:
- a levy on obliged subjects operating under administrative licence — principally financial institutions and gaming operators; and
- a limited percentage of the sanctions it imposes, earmarked for prevention, enforcement and international cooperation activity.
Neither the rate, the base nor the collection mechanism is settled at this stage, and no figure should be assumed. What is settled in principle is the direction: a licensed payment institution, e-money institution or credit institution operating in Spain should expect a recurring supervisory levy as a new line item, in the way firms in other supervised sectors already do.
3. One door to AMLA
The second structural change is external. ANIFI is to be Spain’s single interlocutor before AMLA, the EU Anti-Money Laundering Authority. Today a firm’s supervisory relationships in Spain can involve more than one Spanish body depending on the question; the reform points to one counterparty on the Spanish side facing one counterparty on the EU side.
This is the piece that makes the timing rational rather than arbitrary. The EU package — Regulation (EU) 2024/1624 (AMLR), Directive (EU) 2024/1640 and the AMLA Regulation — is on a runway that requires member states to have their own supervisory architecture in a fit state before AMLA’s direct and indirect supervision starts biting. A member state arriving at that point with competencies split across two bodies has a harder conversation than one arriving with a single authority. Our note on the AML package timeline sets out the EU-side dates this has to meet.
Facts: a Spanish branch of an EEA e-money institution files its monthly SEPBLAC declarations and its FTF returns, and has a designated SEPBLAC representative appointed under Article 26 ter of Ley 10/2010.
What the rule says: the draft bill does not repeal those obligations — it changes who holds them. The financial intelligence unit function, the supervision and inspection function and the sanctioning power all land in one authority.
What the practitioner does: treats this as a mapping exercise rather than a compliance change. Every internal document, policy and procedure that names SEPBLAC — the representative appointment, the reporting procedures, the AML manual, the outsourcing register, the training pack — becomes a search-and-replace list to be executed on commencement, not before.
Outcome: the work is inventory work, and it can be done now while the bill is still in consultation.
4. What is not changing, and why that matters
It is as important to be clear about what this bill does not do. It does not, on the official account, change the substance of what an obliged subject must do day to day: customer due diligence, the reporting of suspicious operations, the systematic monthly declaration, the Fichero de Titularidades Financieras, record-keeping and the internal control obligations all continue to sit in Ley 10/2010 and its implementing regulation. What changes is the institution on the other side of them, plus whatever the alignment with the EU package brings when the operative text is published.
So the sensible reading for a compliance function is: no change of substance to plan for yet, one change of counterparty to inventory, and one new cost line to flag to finance. The things worth re-reading now are the ones that name the authority explicitly — see our notes on what SEPBLAC does, the representative appointment on form F22 and the monthly declaration.
Facts: a compliance officer is asked by the board whether ANIFI means the firm’s AML programme has to be rebuilt before year end.
What the rule says: the bill is an anteproyecto approved at first reading and sent to public consultation. It has not been through the Council of State, has not been approved at second reading, has not been presented to the Cortes and has no commencement date.
What the practitioner does: answers no, and reframes the question — the deliverable this year is a mapping of every reference to the current authorities and a budget flag for the levy, not a programme rebuild. The programme rebuild, if one is needed, will be driven by the AMLR, which is directly applicable and has its own timetable, not by the Spanish institutional reform.
5. FAQ
Is SEPBLAC being abolished?
On the official account its competencies are being unified into ANIFI, together with those of the Secretariat of the Commission for the Prevention of Money Laundering. Until the operative text is published, treat SEPBLAC as your counterparty and the change as one of institutional architecture rather than of obligation.
When does this take effect?
There is no date. The draft bill was approved at first reading on 28 July 2026 and sent to public consultation; it then has to complete its remaining processing before it can be presented to the Cortes and passed. This is an earlier stage than a bill already before Parliament.
Will we have to pay a supervisory levy?
The funding model names a levy on obliged subjects operating under administrative licence — principally financial institutions and gaming operators — plus a limited percentage of sanctions imposed. No rate or base has been set, so treat it as a budget flag rather than a number.
Does this change our reporting obligations?
Not of itself. Customer due diligence, suspicious-operation reporting, the monthly declaration, the FTF and internal control obligations sit in Ley 10/2010 and are not, on the official account, the object of this reform. What changes is who receives and supervises them, and separately what the alignment with the 2024 EU package brings.
What is the proliferation-financing point?
ANIFI is to take on supervision of the financing of proliferation of weapons of mass destruction, described as a competence not previously assigned to any Spanish authority. Firms that have handled this only as a sanctions-screening matter should expect a supervised obligation with an owner.
How does this relate to AMLA?
ANIFI is to be Spain’s single interlocutor before the EU Anti-Money Laundering Authority. The reform is explicitly framed as aligning Spain with the 2024 EU AML package and FATF standards, which is what makes its timing tied to the EU runway rather than to domestic politics alone.
6. What to do, today
- Inventory every reference to the current authorities. The representative appointment, the AML manual, reporting procedures, the training pack, outsourcing documentation and any customer-facing wording. This is the only work that is certain to be needed and it can be done now.
- Flag the levy to finance as a risk, not a number. The perimeter — obliged subjects under administrative licence — is drafted, the rate is not.
- Decide whether to respond to the consultation. First reading plus public consultation is the stage at which perimeter questions actually move, and the branch-versus-entity question on the levy is a real one for passporting firms.
- Give proliferation financing an owner. If it currently lives inside sanctions screening with no named responsible person, the new supervisory competence is a reason to fix that independently of when the bill passes.
- Do not rebuild the programme for this. The substantive driver is the AMLR and its timetable; this bill changes the institution.
One caveat on sourcing, and it is a real one: at first reading the published account of an anteproyecto is a summary, not an operative text. Everything above follows the official account of the Council of Ministers of 28 July 2026. Article numbers, the levy mechanics and the transitional arrangements will only be readable when the consultation text is published, and this page will need revisiting then.
Related: What is SEPBLAC? · the EU AML package timeline · the SEPBLAC representative and form F22 · how to file a SAR in Spain · AMLR governance — compliance manager and officer
