The Spanish Securities Commission (CNMV) has published the results of a 2024 supervisory review of how prudentially supervised entities comply with the legal requirement to maintain a money laundering risk analysis, identifying a considerable number of weaknesses. The review covered around 20 entities, including investment services firms, collective investment scheme management companies, closed-ended fund managers and branches of EU firms. While most entities produce board-approved risk analysis reports and update them periodically, CNMV found that reports often follow Sepblac’s recommended structure without providing a practical picture of the firm’s actual activity, limiting their usefulness as a “business x-ray” to support an effective prevention system. Further shortcomings included insufficient assessment of risks arising from the use of agents and third-party distributors and unclear allocation of AML responsibilities in distribution arrangements, limited consideration of the elevated risk from remote customer onboarding, and reminders that allowing cash movements increases AML risk. CNMV also noted that few entities factor in national and supranational risk assessments, including those published by the Treasury (2024 addendum) and those produced by the European Commission and the European Banking Authority, which the 2024 EU anti-money laundering regulation (not yet applicable) will explicitly require. CNMV has communicated the identified issues to each entity individually and will take them into account in future supervisory work. The review was conducted following the June 2023 cooperation agreement between CNMV and the Commission for the Prevention of Money Laundering and Monetary Offences, under which CNMV assumed supervisory and inspection powers for obliged entities it prudentially supervises under Spain’s anti-money laundering law.
Spanish Securities Commission (CNMV) 2025-02-20
Spanish Securities Commission publishes AML risk assessment review and identifies widespread weaknesses across supervised entities
The Spanish Securities Commission (CNMV) published findings from a 2024 supervisory review revealing significant weaknesses in money laundering risk analysis among prudentially supervised entities. The review highlighted inadequate risk assessments, unclear AML responsibilities, and insufficient consideration of national and supranational risk assessments. CNMV has communicated these issues to the entities and will incorporate them into future supervisory activities.