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PASSPORT CONTROL · AML/CFT

Nothing to declare?

Transactions pass through your office every day. Your team has to be able to spot the one that does not add up, and since October 2026 your company needs a representative before Sepblac (Spain’s financial intelligence unit) with training it can evidence. Three hours per person, per sector, with an exam and a named accreditation. You buy it without any calls.

Prevention of money laundering and terrorist financing · Syllabus 2026.11

SCANNER · TRANSACTION 1 OF 3ESTATE AGENCY

  • €48,000 in cash
  • In a hurry to sign
  • Does not ask the price

A buyer wants to leave a €48,000 deposit in cash and sign this very week. They have not asked the price.

Which channel does it go through? · Made-up transactions, for practice.

Passport control

What you have to declare

Three boxes, with the article next to each. No surprises and no small print.

BOX 1

Since October 2026, small businesses too

Royal Decree 813/2026 removes the exception that exempted obliged entities with fewer than 10 people and up to €2 million from appointing a representative before Sepblac: almost all estate agencies, advisory firms, law firms and jewellers. They have nine months from its entry into force to notify the appointment.

Sources: Real Decreto 813/2026, de 7 de octubre: preámbulo, artículo quinto y disposición transitoria segunda (BOE) (dated 08/10/2026) · Real Decreto 304/2014 (Reglamento de la Ley 10/2010), artículo 31.1 (BOE, texto consolidado) (dated 08/10/2026)

BOX 2

The representative has to be trained

For those who do not have to approve an annual training plan, the Regulation asks for something else: ‘to evidence that the representative before the Executive Service of the Commission has received adequate external training for the exercise of their functions’.

Source: Real Decreto 304/2014 (Reglamento de la Ley 10/2010), artículo 39 (BOE, texto consolidado) (dated 08/10/2026)

BOX 3

And the team has to know what to look for

Article 29 of the Act asks for ‘the duly accredited participation of employees in specific ongoing training courses’. Whoever deals with the customer is the one who identifies, detects and keeps quiet: obligations from which no company is exempt, whatever its size.

Source: Ley 10/2010, de prevención del blanqueo de capitales y de la financiación del terrorismo, artículo 29 (BOE, texto consolidado) (dated 30/09/2026)

Source: Real Decreto 813/2026, de 7 de octubre: preámbulo, artículo quinto y disposición transitoria segunda (BOE) (dated 08/10/2026)

The scanner

The route through the terminal

Six checkpoints for everyone and one gate depending on the sector. Three hours in total, in bits and pieces.

Course syllabus
CheckpointModuleDurationGate
PB-01Why it lands on your desk20 MINEVERYONE
PB-02Passport control20 MINEVERYONE
PB-03Three lanes and a watchlist20 MINEVERYONE
PB-04The scanner20 MINEVERYONE
PB-05Red channel20 MINEVERYONE
PB-06What is kept and who answers for it20 MINEVERYONE
SEC-INMEstate agencies and property developers40 MINBY SECTOR
SEC-ASETax advisers, accountants, gestorías and auditors40 MINBY SECTOR
SEC-ABOLaw firms and court representatives40 MINBY SECTOR
SEC-COMJewellers, art and antiques dealers, valuables40 MINBY SECTOR
HAB-RESPRepresentative before Sepblac and management40 MINREPRESENTATIVE
EXAExam20 MINEVERYONE

Exam: 20 situation questions, passed with 16. Two attempts, with 12 hours between them. Available in: Spanish, Catalan, English.

What goes through the checkpoint with you

Everything included in every plan, for 12 months.

  • CUR

    The course, by sector

    A six-module common core and your sector module: estate agency, advisory firm, law firm, or jeweller’s and art. Short reading, counter-side cases and a simulator.

  • ACR

    Named accreditation

    Whoever passes the exam receives theirs, with their name, hours, date, syllabus version, sector and score. Anyone can verify it with its code.

  • REP

    Representative module

    The external training for whoever represents the company before Sepblac: the role, the special review and the suspicious transaction report. Their accreditation says so expressly.

  • DOS

    Accreditation dossier

    The black box: who, when, for how long, what score and on which syllabus. What you show to an external expert or in an inspection.

  • PLA

    Annual training plan

    Mandatory if there are 10 or more of you or you exceed €2 million; voluntary if not. In both cases the platform fills it in for you.

  • TUT

    Tutor in writing

    Questions about the syllabus through the board and the platform inbox. Reply within 48 working hours at most.

How it works

  1. 01

    You tell us how many of you there are, which sector and who the representative is

    The assistant gives you the fixed price. You pay by card and receive the invoice.

  2. 02

    You sign up the team

    From your control tower: by pasting a list or sharing a link. Each person receives their access by email, with no passwords.

  3. 03

    Everyone takes it at their own pace

    Three hours spread however they like. The platform remembers where they left off.

  4. 04

    Exam and accreditation

    Twenty situation questions. Whoever passes has their accreditation straight away and you see it in the tower.

  5. 05

    You keep the dossier

    Annual plan and dossier, ready to print or save as PDF when they are asked for.

Common core

The whole team takes it, in this order.

  1. PB-01

    20 min

    Why it lands on your desk

    • What money laundering is
    • Why it falls to you
  2. PB-02

    20 min

    Passport control

    • Identify: the document comes first
    • Who is behind it, and why
  3. PB-03

    20 min

    Three lanes and a watchlist

    • Not everyone goes through the same lane
    • The watchlist
  4. PB-04

    20 min

    The scanner

    • What doesn't fit
    • Cash, and how to take notes
  5. PB-05

    20 min

    Red channel

    • What you do and what the representative does
    • Don't tip off the passenger
  6. PB-06

    20 min

    What is kept and who answers for it

    • Ten years
    • The house from the inside

Your sector

You choose your company’s when you buy. Each person takes one.

  • SEC-INM

    40 min

    Estate agencies and property developers

    For anyone who wins instructions, shows and sells property, signs reservations and deposit contracts, or handles the admin at an estate agency or a property developer.

    • What the law requires of you, and who you look at
    • Your sector's catalogue, in four families
    • Your day to day: from the viewing to the notary
  • SEC-ASE

    40 min

    Tax advisers, accountants, gestorías and auditors

    For anyone who keeps clients' books, handles their taxes, payroll or companies, at a tax or accounting advisory firm, a gestoría (an administrative agency that handles paperwork for individuals and businesses) or an audit firm.

    • What the law requires of you, and who you look at
    • Your sector's catalogue, in five families
    • Your day to day: from onboarding to each quarter's close
  • SEC-ABO

    40 min

    Law firms and court representatives

    For lawyers, procuradores (court representatives), trainees and administrative staff at law firms who take part in sales, company work, client funds and other transactions covered by article 2.1.ñ of Act 10/2010.

    • When the firm is covered and when it is not
    • The law firm catalogue
    • Taking on an instruction, step by step
  • SEC-COM

    40 min

    Jewellers, art and antiques dealers, valuables

    For shop assistants, managers and owners of jewellers, gold buyers, galleries, antiques dealers and auction houses, and for any business that takes large cash payments from non-resident customers.

    • Three ways in
    • The counter catalogue
    • The sale, step by step

For the representative

The external training for the representative before Sepblac. It is added to their sector module.

  • HAB-RESP

    40 min

    Representative before Sepblac and management

    For anyone who has been or is about to be appointed representative before Sepblac, and for the management who appoint them: partners, directors and managers of businesses that are obliged entities under Act 10/2010.

    • The role: who, how and by when
    • The special review, step by step
    • Reporting, and afterwards

What this course is not

  • It is not an official qualification or an approval. The accreditation is a Formativia diploma, verifiable, and it says exactly what it evidences.
  • It does not replace your company’s other obligations (identifying customers, keeping records, reviewing and reporting transactions): it teaches your team to meet them.
  • It is not legal advice. For your company’s prevention manual or external review you need your adviser.

Fares

One payment by team size. Everything included, 12 months.

  • Formativia · MON

    Monoplaza

    One professional, or just the representative

    Passengers
    1 person
    Per person
    €79

    €79+ VAT

  • Formativia · AVN

    Avioneta

    For small practices and teams

    Passengers
    Up to 5 people
    Per person
    €29.80

    €149+ VAT

  • Formativia · ESCRecommended

    Escuadrilla

    The one we recommend: a whole small company

    Passengers
    Up to 15 people
    Per person
    €23.27

    €349+ VAT

  • Formativia · FLT

    Flota

    Several departments at once

    Passengers
    Up to 30 people
    Per person
    €19.67

    €590+ VAT

  • Formativia · AER

    Aerolínea

    The whole company, with seats to spare

    Passengers
    Up to 60 people
    Per person
    €16.50

    €990+ VAT

  • Monoplaza is a single seat: for the individual professional, or to train the representative first.
  • More than 60 people: €15 + VAT per additional seat.
  • The accreditation carries the date and the syllabus version and is valid for 12 months on the platform. We will let you know a month beforehand, in case you want to repeat it with the updated syllabus.
  • Prices exclude VAT.

We open shortly

The syllabus is being reviewed by a money laundering prevention expert. Leave us your email and we will let you know the day it opens. One email only; afterwards we delete it.

Frequently asked questions

Who in my company has to do it?

Definitely the representative before Sepblac: the Regulation asks that you be able to evidence that they have received adequate external training (art. 39.4). For everyone else, article 29 of the Act speaks of ‘their employees’, and they are the ones who identify the customer, detect what does not add up and have to know to keep quiet. The sensible course is to train everyone who deals with customers or their transactions.

There are three of us. What exactly applies to us?

With fewer than 10 people and up to €2 million, the Regulation exempts you from written procedures, the documented risk analysis, the manual, the external review and the annual training plan (arts. 31, 32, 33, 38 and 39). You remain bound by everything else: identifying, knowing the beneficial owner, reviewing, reporting, not tipping off, keeping records for ten years, appointing a representative and evidencing that the representative has received adequate external training (art. 39.4). On the training of the rest of the team: article 29 of the Act requires employees to know their obligations and contains no exception; Sepblac’s website presents these businesses as exempt from the annual plan and leaves the representative’s training as the requirement; whoever deals with the customer applies in person obligations from which nobody is exempt; and from 10 July 2027 article 12 of Regulation (EU) 2024/1624 requires continuing, documented training from every obliged entity, with no size threshold.

Does it count as the representative’s external training?

The representative module is designed for that: it is delivered by a third party, focuses on their functions (the role, the special review, the suspicious transaction report) and ends with an exam and a dated named accreditation. Whether it is ‘adequate’ is for the supervisor to judge: nobody can guarantee it in advance, and you should be wary of anyone who does.

Is it approved by Sepblac?

No, neither this one nor any other: approval does not exist. Sepblac itself says so in its frequently asked questions: the law ‘does not oblige these courses to be bought externally, nor does it specify who must deliver them. Nor does it establish criteria for approval or validation of training programmes’. The accreditation is a Formativia diploma, verifiable, and it says exactly what it evidences.

How often does it have to be repeated?

‘Annual’ is only literal for whoever must have an annual training plan: 10 or more people, or more than €2 million. For small businesses, neither the Act nor the Regulation sets how often the representative is trained. The Formativia accreditation carries the date and the syllabus version and is valid for 12 months on the platform because the rules change: in July 2027 the European regulation starts to apply, and it speaks of continuing training.

I am a professional with no employees. Which plan do I take?

Monoplaza: one seat. For an individual business owner or professional, the representative before Sepblac is the owner of the activity, so the course includes for you the module for your sector and the representative’s.

What does each person receive?

Their named accreditation when they pass: course, hours, date, syllabus version, sector and score, with a code that anyone can check at formativia.com/verificar.

And if someone fails?

They have two attempts, with twelve hours between them to revise. If they use up both, you can give them another from the control tower.

Which languages is it in?

The platform is in Spanish, Catalan and English. Each person chooses theirs; if a syllabus language is not yet published, they see it in Spanish.

Can I get it subsidised?

We do not advertise it as subsidisable. The market says all sorts, from “100% subsidisable” to the claim that training required by law cannot be subsidised, and we have not found an official criterion that settles it. Ask your gestoría; we do not process it.

Do I also get the AI course?

They are two separate purchases, each with its own control tower. The AI one is for any company whose team uses AI at work.

Sources: Real Decreto 304/2014 (Reglamento de la Ley 10/2010), artículo 31.1 (BOE, texto consolidado) (dated 08/10/2026) · Real Decreto 304/2014 (Reglamento de la Ley 10/2010), artículo 39 (BOE, texto consolidado) (dated 08/10/2026) · Ley 10/2010, de prevención del blanqueo de capitales y de la financiación del terrorismo, artículo 29 (BOE, texto consolidado) (dated 30/09/2026) · Sepblac, «Preguntas frecuentes» de sujetos obligados (dated 13/11/2026) · Reglamento (UE) 2024/1624, artículos 12 y 90 (EUR-Lex) (dated 19/06/2024)

Green channel for your team

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