Anti-Money Laundering

[PENDIENTE_RAZON_SOCIAL] is an obliged entity under Law 10/2010 of 28 April, on the Prevention of Money Laundering and Terrorist Financing, and operates an internal programme aligned with Directives (EU) 2015/849 and (EU) 2018/843.

Obliged entity

As a legal-tax firm providing commercial, tax and corporate advisory services, [PENDIENTE_RAZON_SOCIAL] is subject to the anti-money laundering and counter-terrorist financing regime. This entails obligations of identification, due diligence and reporting to SEPBLAC regarding certain transactions.

Due diligence

Before initiating any professional relationship, the firm applies due diligence measures that include:

• Formal identification of the client through official documentation.
• Identification of the beneficial owner when the client is a legal entity.
• Understanding of the purpose and nature of the professional relationship.
• Continuous monitoring of the relationship throughout its duration.
• Enhanced assessment for high-risk operations (PEPs, high-risk jurisdictions, complex or unusual transactions).

Suspicious transactions

The firm maintains an AML Manual and an internal control body that examines any transaction that may be linked to money laundering or terrorist financing. Where applicable, the corresponding report is filed with SEPBLAC (Executive Service of the Commission for the Prevention of Money Laundering) or the equivalent body in each jurisdiction.

Training and supervision

All professionals receive mandatory periodic training on AML matters. Compliance with the programme is supervised by the Compliance Committee and by an independent external expert, as required by regulation.

Refusal to provide service

[PENDIENTE_RAZON_SOCIAL] reserves the right not to engage or to terminate the professional relationship when it is unable to complete the due diligence measures required by regulation, or when there are well-founded indications that the transaction may be linked to money laundering or terrorist financing.