New Anti-Money Laundering Council 2026: what banks, insurers and notaries must do

Key data

Banks, insurers and notaries have a new permanent institutional interlocutor from 23 October 2026. The Order ECM/1101/2026 creates the National Council for the Prevention of Money Laundering, Terrorist Financing and Financing of Proliferation of Weapons of Mass Destruction, a body that for the first time structures stable collaboration between the private sector and competent authorities in money laundering prevention.

Until now, that coordination was sporadic and dispersed. With this Council, it becomes structured, permanent and bidirectional: obligated entities will not only receive instructions, but can also propose guides and contribute to national risk analysis.

What does this regulation establish?

Order ECM/1101/2026 creates the National Council assigned to the Commission for the Prevention of Money Laundering and Monetary Infractions. Its internal structure is articulated in three levels:

• Council Plenary: highest decision-making body, with representatives of the main State authorities.
• Executive Committee: management body for monitoring Plenary agreements.
• Sectoral Technical Commissions: specialized working groups by activity sector.

The Council's main functions are:

• Articulate public-private collaboration in a structured and permanent manner.
• Exchange strategic, tactical and operational information between authorities and obligated entities.
• Propose guides and recommendations for compliance by obligated entities.
• Contribute to national risk analysis in money laundering and terrorist financing matters.

The Plenary composition includes representatives from the following bodies:

Economic and operational impact

This regulation does not impose direct fees or sanctions, but its operational impact is significant for any obligated entity under Law 10/2010. The specific changes affecting daily operations are:

• New information exchange channels: obligated entities must adapt to the procedures and formats established by the Council to share strategic, tactical and operational information with authorities.
• New guides and recommendations: the Council may issue compliance guides that, in practice, become reference standards for compliance inspections and audits.
• Participation in national risk analysis: obligated entities may —and in some cases must— contribute information to national risk analysis, which implies new internal processes for data collection and reporting.
• Sectoral technical commissions: each sector (banking, insurance, notarial, etc.) will have its own technical commission, requiring designation of internal interlocutors and active participation in sectoral work.

The cost of adaptation will depend on the size and complexity of each entity, but all must review their internal compliance protocols in money laundering prevention to align with the new channels and standards established by the Council.

Who does it affect?

This regulation directly affects all obligated entities under Law 10/2010, of 28 April, on the prevention of money laundering and terrorist financing. Among them:

• Credit institutions (banks, savings banks, credit cooperatives)
• Insurance entities and insurance brokers
• Investment services companies
• Notaries and property and commercial registrars
• Lawyers and solicitors in certain transactions
• Auditors and tax advisors
• Real estate agents
• Casinos and gaming establishments
• Investment and venture capital fund managers

Practical example

A medium-sized banking entity with its own compliance department receives, through the Council's new channels, a sectoral guide on alert signals in international financing operations issued by the Banking Sectoral Technical Commission.

That guide is not a law, but it is the reference standard that the Bank of Spain —member of the Plenary— will use in its next inspections. The bank must:

1. Review its internal procedures for detecting suspicious transactions in light of the new guide.
2. Update the training of its compliance team.
3. Designate an internal interlocutor to participate in the work of the Sectoral Technical Commission.
4. Adapt its reporting systems to be able to share operational information with authorities in the required format.

The same scheme is replicated for insurers, notarial offices and other obligated entities, each through its corresponding sectoral technical commission.

What should companies do now?

1. Verify if you are an obligated entity under Law 10/2010: if your activity appears in the previous list, this regulation affects you from 23 October 2026.
2. Review internal compliance protocols in money laundering prevention to identify possible gaps regarding the new coordination channels established by the Council.
3. Designate an internal interlocutor responsible for the relationship with the National Council and for participating in the Sectoral Technical Commission corresponding to your activity.
4. Update information reporting systems to be able to exchange strategic, tactical and operational data with authorities in the formats established by the Council.
5. Monitor the guides and recommendations issued by the Council, as they will become the reference standard for compliance inspections and audits.
6. Train the compliance team on the new public-private coordination framework and the operational implications for the entity.

Official source

Consult complete regulation at official source

Disclaimer: This article is for informational purposes only and does not constitute legal advice. For specific decisions, consult a qualified professional. Source: https://www.boe.es/diario_boe/txt.php?id=BOE-A-2026-21952