PBKAsesores
ES

Services

Consultancy, audits, training and technical unit

We cover every obligation the law imposes, from initial compliance set-up and staff training through to external review.

Consulting

Initial adaptation to current legislation and day-to-day compliance oversight. Includes:

  • Internal control procedures, a customer acceptance policy and a catalogue of higher-risk transactions.
  • A manual covering anti-money laundering and counter-terrorist financing procedures.
  • Setting up the Internal Control Body (Órgano de Control Interno, OCI) and, where applicable, the Technical Unit.
  • Appointment of the Representative before SEPBLAC (form F22).
  • A risk self-assessment report.
  • Initial training for employees in risk-exposed roles.

Our consultants study your organization's needs and propose the solutions that best fit your business, providing full support to put them into practice.

Audit

A mandatory annual review of governance bodies and procedures by an external expert, required for obliged entities under art. 2.1 of Spain's Ley 10/2010. Our auditors have been registered in the Special Registry of External Experts of SEPBLAC (Spain's anti-money laundering authority) since 2010, and are members of INBLAC, the association of external experts; our reports follow the format set out in Orden EHA/2444/2007. We have completed more than 900 external audits across a wide range of sectors. Non-compliance is classified as a serious infringement, carrying a minimum fine of €60,001 and up to 1% of the entity's own funds. Exempt from the annual review are sole traders and individual professionals, insurance brokers, and entities under art. 2.1(i)–(u) with fewer than 10 employees and turnover or a balance sheet total below €2 million, unless they belong to a group that exceeds those thresholds.

Training

Design of the annual training plan, submitted for approval by the OCI, together with general courses (basic-level, for all employees) and specific courses aimed at management, the OCI or the Technical Unit. Delivered in person, with our staff travelling to your premises, or remotely online, by qualified instructors, with a final multiple-choice test and an accreditation certificate on completion, in accordance with art. 29 of Ley 10/2010 and art. 39 of RD 304/2014 (the law's implementing regulation).

Technical Unit

Outsourcing of the Technical Unit's functions: mandatory for obliged entities with turnover above €50 million or a balance sheet above €43 million (art. 35 of RD 304/2014), and advisable in all other cases. Includes:

  • Analysis and documentation of transactions and clients.
  • A risk self-assessment report.
  • Review of controls over higher-risk customers and transactions.
  • Screening of the customer base against sanctions lists.
  • Liaison with the OCI and with the Representative before SEPBLAC.
  • Filing indicator-based reports and the mandatory monthly declarations (DMO).
  • Updating the Procedures Manual and the annual activity report.