Spain's Official State Gazette (BOE) on 6 March 2025 published a fine of EUR 3,919,300 and a public reprimand imposed on ING Bank NV's Spanish branch for a very serious breach of the country's anti-money laundering and counter-terrorist financing law.
The sanction was imposed by the Council of Ministers on 4 July 2023, on a proposal from the then First Vice-President of the Government and Minister for Economic Affairs and Digital Transformation, following disciplinary proceedings ST/4005/2022. It was published under a resolution dated 25 February 2025 from the Secretariat of the Commission for the Prevention of Money Laundering and Monetary Offences, the body whose executive service is SEPBLAC.
FAILURE TO REPORT
According to the notice, the infringement falls under Article 51.1(a) of Law 10/2010 of 28 April on the prevention of money laundering and terrorist financing. The breach concerned the duty under Article 18 of the law to report to the authorities where a manager or employee of the obliged entity had internally flagged indications, or certainty, that a transaction or activity was related to money laundering or terrorist financing.
The provision therefore applies to cases in which suspicions had already been raised within the institution itself but the required report to the authorities was not made. Law 10/2010 classifies such a failure as a very serious infringement.
PUBLICATION REQUIREMENT
The sanction was published once it had become final through the administrative channel, in accordance with Article 61.5 of Law 10/2010, which governs the publication of sanctions for very serious infringements. The fine was imposed under Articles 51 and 56 of the law, which classify very serious breaches and set the penalties that apply to them.
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