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pc nid 93719 Jul 03, 2026 tojuri@vixio.com Spain The Executive Service of the Commission for the Prevention of Money Laundering and Monetary Offences (Sepblac) horizon scanning
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Spain's Financial Intelligence Unit Publishes De-Risking Guidance and Proliferation Financing Risk Indicators

On July 2, 2026, the Executive Service of the Commission for the Prevention of Money Laundering and Monetary Offences (Sepblac) announced the publication of two documents by Spain's Public Treasury (Tesoro Público) relevant to the private sector's compliance obligations. The first document is a guidance note on de-risking, which defines the practice, highlights key aspects, and outlines preventive measures. De-risking refers to the practice of financial institutions terminating or restricting business relationships with customers or entire categories of customers to avoid perceived compliance, financial, or reputational risks. The second document is a catalogue of risk indicators relating to the financing of weapons of mass destruction proliferation. This catalogue complements existing risk indicator catalogues previously published and aims to assist financial institutions and other obligated entities in identifying transactions and activities related to proliferation financing risks. Both documents are designed to support the private sector in meeting its anti-money laundering and counter-terrorism financing obligations under Spanish law. The de-risking guidance addresses a significant compliance challenge, as excessive de-risking can undermine financial inclusion and market access for legitimate businesses and customers. The proliferation financing risk indicators provide practical tools for detecting suspicious activity related to weapons of mass destruction financing, a priority area under international sanctions regimes and Financial Action Task Force (FATF) recommendations. The documents are available on Sepblac's website and through the Public Treasury's publications portal. Financial institutions, money service businesses, and other regulated entities should review these materials to enhance their risk identification and mitigation procedures.

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Spain's Public Treasury Publishes De-Risking Guidance and Proliferation Financing Risk Indicators

Spain’s Public Treasury has published guidance for regulated entities on de-risking and a catalogue of risk indicators related to financing the proliferation of weapons. The purpose of the guidance is to clarify the scope and application of the risk-based approach in relations between obliged entities and their customers with a view to reducing instances of de-risking that lead to financial exclusion for certain groups. The guidance defines the practice, highlights key aspects and outlines preventive measures for de-risking, addressing a significant compliance challenge: excessive de-risking can undermine financial inclusion and market access for legitimate businesses and customers. In addition to publishing the de-risking guide, the Public Treasury has also published a catalogue of risk indicators related to the financing of weapons of mass destruction proliferation. The proliferation financing risk indicators provide practical tools for detecting suspicious activity related to weapons of mass destruction financing, a priority area under international sanctions regimes and Financial Action Task Force (FATF) recommendations. Financial institutions, money service businesses and other regulated entities are encouraged to review the guides to enhance their risk identification and mitigation procedures.