Anti-money laundering for lawyers: obligations and latest SEPBLAC rulings 2025
Lawyers are obliged entities under Law 10/2010 AML when involved in certain transactions (property sales, company formation, fund management). We cover due diligence duties, SEPBLAC reporting and professional secrecy.
Are lawyers obliged entities?
Yes, but only for certain activities. Art. 2.1.ñ of Law 10/2010 of 28 April on the prevention of money laundering and terrorist financing includes lawyers when, in the exercise of their professional activity, they participate in:
- Sales of real estate or commercial entities.
- Management of client funds, securities or other assets.
- Opening or managing bank accounts, deposits or securities portfolios.
- Organising contributions for the formation, management or administration of companies.
- Formation, management or administration of trusts or similar structures.
Not subject when providing legal advice, defence or procedural representation, though they must apply professional judgment if they detect money laundering indicators during any advisory work.
SEPBLAC communication
The obliged lawyer must report to SEPBLAC any transaction showing signs of being related to money laundering (Art. 18 Law 10/2010), unless the information was obtained in the context of defence or procedural representation or in legal advice before or after judicial proceedings.
This exception preserves professional secrecy (Art. 22.2 Law 10/2010), confirmed as compatible with EU law by the CJEU (C-305/05 Ordre des barreaux francophones).
Try Lexiel free · 28 days
Use code LEX-BLOG for double the standard trial period. Cancel anytime, no commitment.