Spain establishes national AML council to strengthen financial oversight

Spain has formally established a new national framework intended to improve cooperation between public authorities and regulated businesses in the fight against money laundering. An order published in the Spanish Official State Gazette on 22 October 2026 creates the National Council for the Prevention of Money Laundering, Terrorist Financing and the Financing of the Proliferation of Weapons of Mass Destruction. The body is designed to support a more coordinated approach to AML risks across sectors, including parts of the gambling industry.

The measure forms part of Spain’s broader effort to improve intelligence sharing and identify emerging money laundering risks. It creates a forum for cooperation rather than a new enforcement authority with independent sanctioning powers.

A formal channel for public-private cooperation

The Council will operate under the Commission for the Prevention of Money Laundering and Monetary Offences. Its role is advisory and consultative, bringing together representatives from government institutions and private-sector entities that fall within Spain’s anti-money laundering rules.

The Council will give authorities and regulated businesses a regular forum to discuss risks and prevention measures. Banks, gambling-related entities and other covered sectors may hold different information about transactions and customer activity, so coordination could help reveal patterns that individual organisations might not identify alone. Public bodies will have permanent representatives, while regulated sectors will be represented through non-permanent members.

This structure is intended to strengthen communication between policymakers, enforcement institutions and businesses that must comply with financial crime prevention requirements. It also provides a framework for discussing emerging risks without replacing the legal responsibilities of individual entities.

Duties include risk analysis and recommendations

The Council’s functions include promoting cooperation between authorities and regulated entities, facilitating the exchange of strategic and operational information and contributing to Spain’s national risk analysis and anti-money laundering strategy. It may also propose reports, guidance and recommendations on vulnerabilities, emerging threats and possible improvements to the national prevention system.

The Council may establish an executive committee of up to ten members and specialist technical committees for sector-specific questions. It must meet at least once a year, with additional meetings possible when required.

Its reports and recommendations will not be binding. The distinction is important for regulated entities: the Council is intended to support dialogue, improve risk awareness and help shape policy, while existing legislation and competent supervisory authorities continue to determine the legal obligations that apply to each business.

The Council must be formally constituted within one month of the order taking effect. Its work is to be funded through existing staff, technical resources and budgets.

Gambling operators face more specific payment checks

The Council arrives as Spain makes separate changes to anti-money laundering controls for online gambling. Royal Decree 813/2026, published earlier in October, updates the regulatory framework and requires operators to verify that the person who owns the payment method used for deposits and withdrawals is the same person registered as the holder of the gambling account.

The decree is scheduled to take effect on 28 October 2026 and provides a six-month transition period for existing accounts and technical updates. During that period, users may continue depositing and playing with existing payment methods, but prize withdrawals are restricted until the required verification is complete. Operators must handle accounts that remain unverified after the transition in accordance with the decree.

The payment check is intended to connect a gambling account with the financial instrument used to deposit or withdraw money, reducing the potential for activity through payment methods controlled by someone else. Operators will need reliable account data, customer communications and procedures for unresolved ownership mismatches.

These requirements form part of a wider effort to improve payment transparency and strengthen the verification of customer identities. They also highlight the importance of coordination between compliance teams, payment providers and the operational departments responsible for account management.

Other reported gambling-related fee changes should be considered separately from these national AML measures. Administrative fees can fall under regional rules, so such changes should not be described as fees created by the new Council order unless the relevant legislation expressly establishes that connection.

Lottery tickets remain a potential laundering route

Lottery winnings can also be misused to disguise the origin of illicit funds. A person may buy a winning ticket from its legitimate holder and present the eventual prize as the proceeds of a lawful win. Spanish authorities have previously referred to winning tickets in investigations into suspected laundering activity.

Some reports have described alleged offers to pay ticket holders a premium above the prize amount, with figures of around 20% appearing in media accounts. That number should be treated as a reported figure rather than an official estimate of how common the practice is.

Reports have also discussed alleged cases in which information about a pending prize deposit was shared with others. These allegations are separate from the new Council order and should not be taken as proof of wrongdoing by any particular bank, employee or lottery winner.

The risk illustrates why identity checks around prize payments matter. Loterías y Apuestas del Estado, Spain’s state lottery operator, explains that prize collection can require identity documents and additional customer information to meet AML requirements. Such safeguards help establish who is entitled to a prize and create a record of the transaction.

What the framework means for compliance teams

The Council does not replace each business’s own AML programme. Regulated entities should continue customer due diligence, transaction monitoring, recordkeeping and escalation processes suited to their services, while respecting applicable privacy and confidentiality rules.

The Directorate-General for the Regulation of Gambling (DGOJ) remains relevant to the supervision of state-level gambling activities. Its regulatory role sits alongside the wider framework for preventing financial crime, meaning operators must consider both gambling-specific requirements and their separate anti-money laundering obligations.

For gambling compliance teams, the Council’s advisory role should be considered alongside the separate payment verification changes. Operators will need consistent procedures for checking customer identity and payment ownership, documenting exceptions and resolving mismatches. Implementation decisions should follow the legal text and formal regulatory guidance.

The wider regulatory direction also increases the importance of maintaining reliable records and responding appropriately to potential suspicious activity. Businesses should ensure that internal controls are proportionate to the risks associated with their products, payment flows and customer relationships.

Conclusion

Spain’s National AML Council creates a formal structure for closer engagement between authorities and regulated sectors, focusing on information sharing, risk analysis and practical recommendations. Although its conclusions are non-binding, the forum may help identify shared vulnerabilities and improve coordination.

For gambling operators, the Council sits alongside a broader shift towards transparent payment flows and reliable customer identification. Its impact will depend on meaningful information exchange and consistent implementation of existing obligations. AML compliance in Spain is increasingly framed as a shared responsibility, supported by cooperation between institutions and effective controls within individual businesses.

FAQs

What is Spain’s National AML Council?
It is a national advisory and consultative body established to improve cooperation between public authorities and regulated private-sector entities on money laundering, terrorist financing and related financial risks.

When was the National AML Council announced?
The establishing order was dated 16 October 2026 and published in the Spanish Official State Gazette on 22 October 2026.

Which authority will the Council operate under?
The Council operates under the Commission for the Prevention of Money Laundering and Monetary Offences, which coordinates relevant prevention activities within Spain’s public administration.

Will the Council have the power to impose fines?
The Council has an advisory and consultative role. Its reports and recommendations are non-binding, while existing legal and supervisory powers remain with the competent authorities.

How frequently must the Council meet?
The Council must meet at least once a year. Additional meetings may take place when necessary under the procedures established by its governing order.

How could the Council affect gambling operators?
The Council provides a framework for exchanging information and discussing risks affecting regulated industries, including relevant gambling businesses. It does not automatically replace or change each operator’s existing legal obligations.

What payment verification rules are changing in Spain?
Royal Decree 813/2026 requires online gambling operators to verify that the owner of the payment method used for deposits and withdrawals matches the registered gambling account holder.

When do the new payment verification requirements take effect?
The decree is scheduled to take effect on 28 October 2026. It also establishes a six-month transition period for existing accounts and the technical changes required by operators.

How can winning lottery tickets be associated with money laundering?
A suspected method involves purchasing a winning ticket from its legitimate holder and then presenting the prize proceeds as legitimate income. Such activity depends on the circumstances of the case and should not be assumed to occur in every lottery transaction.

What should gambling operators do to strengthen AML compliance?
Operators should review customer identification procedures, payment ownership checks, transaction monitoring and recordkeeping. They should also follow applicable legislation and formal regulatory guidance when implementing new requirements.