The Council of Ministers approved on July 28, in the first round, the Draft Law on comprehensive measures in the prevention of money laundering, the financing of terrorism, and the financing of the proliferation of weapons of mass destruction. Its central piece is the creation of the National Authority for Financial Integrity (ANIFI), an agency called to unify in a single structure the competencies that today are divided between Sepblac and the Secretariat of the Commission for the Prevention of Money Laundering and Monetary Offenses.
The text, which is now submitted to public hearing until September 30, does not create the ANIFI from scratch: the new authority arises from the transformation of the FROB, which loses its functions of executive banking resolution (which pass to the Bank of Spain and the CNMV) and is entirely reconverted into the new authority of financial integrity, retaining its legal personality and its current budgetary and tax regime.
Parliamentary and Judicial Control
The draft configures the ANIFI as an independent administrative authority that will act with organic and functional autonomy, outside the Government and any public or private entity in the exercise of its functions. If approved in the terms proposed by the Executive, it will relate to the Ministry of Economy, Trade and Business through the State Secretariat for Economy and Business Support, although the text itself specifies that this link "under no circumstances" may affect its autonomy and independence.
The new authority will assume the role of the country's single financial intelligence unit, with the capacity to receive and analyze communications of suspicious operations from obligated subjects, information sent by customs, and data from other supervisors. This function is complemented by the supervision and inspection of regulatory compliance, the power to issue circulars and technical instructions, and the instruction and resolution of sanctioning files, including the imposition of coercive fines.
The agency will also have a voice in granting licenses to new obligated entities, assessing the suitability of administrators and beneficial owners, managing international financial sanctions and fund freezes linked to proliferation financing, and will be the Spanish interlocutor before the future European Anti-Money Laundering Authority (AMLA).
A Governing Commission
The government of the ANIFI will fall under two bodies: the Presidency and the Governing Commission. The Presidency will be appointed by royal decree from the Council of Ministers, at the proposal of the head of Economy, for a term of five years, after consultation with the Commission for the Prevention of Money Laundering. The Governing Commission, for its part, will include (in addition to the Presidency) permanent representatives from the Ministry of Economy, the Bank of Spain, the CNMV, the General Directorate of Insurance and Pension Funds, and the ministries of Finance, Interior, and Presidency or Justice, all of them with a minimum rank of Secretary of State.
This collegiate body will have non-delegable functions such as the approval of the budget and the annual accounts, the internal regime regulations, the code of conduct for personnel, and the initiation and resolution of sanctioning procedures. All obligated subjects must also designate a representative before the ANIFI, which will allow the authority to have a complete census to apply risk-based supervision.
Own Financing
One of the features that the Ministry of Economy emphasizes in its presentation of the draft bill is that the ANIFI will have an autonomous financing system, without depending on the General State Budgets. It will be funded by a fee applied to obligated subjects subject to administrative license — mainly financial entities and gaming operators — and a limited percentage of the sanctions imposed by the authority itself, intended to finance its prevention and international cooperation tasks.
New Obligated Subjects
Beyond the institutional design, the draft bill significantly expands the catalog of obligated subjects to comply with anti-money laundering regulations. Among others, it includes providers of cryptoasset services, crowdfunding platforms, and, as the most striking novelty, professional football clubs and agents. The reform also strengthens transparency regarding beneficial ownership, with new inspection and sanctioning powers over the Central Registry, and tightens the suitability requirements to prevent individuals convicted of money laundering from acting as obligated subjects or directing them.
The Government frames this update as the largest revision of the Spanish anti-money laundering system in more than three decades, with which it seeks to respond to the rise of crypto assets and the increasingly sophisticated techniques of criminal networks, in addition to preparing the country for the mutual evaluation that the FATF will initiate on Spain throughout 2026.
Still without a date to reach Congress
The reform responds to the dual objective of strengthening the Spanish institutional architecture in the fight against money laundering and adapting national regulations to the European anti-money laundering package approved in 2024 (the EU regulations 2024/1624 and 2023/1113) as well as to the requirements of the Financial Action Task Force (FATF), in view of the mutual evaluation that the body will initiate on Spain in 2026.
Despite the ambition of the project, the text is still in the public hearing phase and has not been sent to the General Courts, so Sepblac and FROB continue, for now, exercising their current competencies in a transition context already announced by the Government.