AutoSmart GuidebooksWhat this guidebook covers
Since 2021, payments of €1,000 or more cannot be made in cash when one party is a business. The AEAT (Spanish Tax Agency) fines both the payer and the receiver 25% of the amount: a €3,000 cash deposit means a €750 fine for each. If the dealer is an obliged entity under the Anti-Money Laundering Act (Law 10/2010), very serious infringements start at €150,000.
This guidebook covers 5 cash and anti-money laundering standards, with 14 checkpoints: the cash limit, customer identification, suspicious transactions reported to SEPBLAC, the manual and training, and preparation for the EU AML Regulation that applies from 10 July 2027. The guidebook PDF is in Spanish.
The 5 cash and anti-money laundering standards
Open a standard to see the law behind it, what is checked, what it can cost and the evidence. Ideal fix times are counted from audit submission.
BLA-01Cash limitImmediate
- The law
- Law 7/2012 art. 7 (cash payment limit, amended by Law 11/2021) · Law 10/2010 on the prevention of money laundering · Law 7/2012 art. 7: payments of €1,000 or more can't be made in cash in transactions with businesses
- What we check
- The cash desk doesn't accept €1,000 or more in cash per transaction (including the deposit), or split payments to get round the limit.
- What it can cost
- 25% of the payment, for both parties.
- Evidence
- Cash counts + receipts
BLA-02Customer identification72 hours
- The law
- Law 7/2012 art. 7 (cash payment limit, amended by Law 11/2021) · Law 10/2010 on the prevention of money laundering · Law 10/2010 arts. 3–4: identification and beneficial owner (if the dealer is an obliged entity)
- What we check
- Where Law 10/2010 applies, the customer is identified with a document, the beneficial owner is checked if the buyer is a company, and the source of funds is known. Applies to dealers subject to Law 10/2010 (art. 2.1.q), for example because of cash payments from non-residents.
- What it can cost
- Very serious: from €150,000.
- Evidence
- Customer files
BLA-03Suspicious transactions24 hours
- The law
- Law 7/2012 art. 7 (cash payment limit, amended by Law 11/2021) · Law 10/2010 on the prevention of money laundering · Law 10/2010 arts. 17–18 and 24: special review, reporting to SEPBLAC and ban on disclosure
- What we check
- Unusual transactions are reviewed and, where there are signs, reported to SEPBLAC. The customer is never told.
- What it can cost
- Very serious: from €150,000.
- Evidence
- Internal register
BLA-04Manual and training30 days
- The law
- Law 7/2012 art. 7 (cash payment limit, amended by Law 11/2021) · Law 10/2010 on the prevention of money laundering · Law 10/2010 arts. 26–29: internal control, representative to SEPBLAC and training
- What we check
- If the dealer is an obliged entity: a prevention manual, a risk analysis, a representative to SEPBLAC and annual training. Applies to dealers subject to Law 10/2010.
- What it can cost
- Serious: from €60,000.
- Evidence
- Documents
BLA-05AMLR 2027 preparation30 days
- The law
- Law 7/2012 art. 7 (cash payment limit, amended by Law 11/2021) · Law 10/2010 on the prevention of money laundering · Regulation (EU) 2024/1624: sellers of high-value vehicles · EU cash limit
- What we check
- The dealer is preparing for the EU regulation from July 2027: it identifies high-value sales and reviews its processes.
- What it can cost
- Penalties under the new rules.
- Evidence
- Plan
How to run a Spanish cash payments and anti-money laundering audit, step by step
- Confirm what applies. The cash limit always applies. Law 10/2010 only applies to dealers in the cases set out in its article 38, for example cash from non-residents: confirm whether you are an obliged entity.
- Walk the site, standard by standard. Score each of the 14 checkpoints Pass, Fail or N/A. N/A only where the standard rules it out, with the reason recorded. Review 3 months of cash records for payments of €1,000 or more and split payments, check 10 deal files for ID and source of funds, and ask 3 salespeople what they do with a suspicious deal.
- Capture the evidence. A pass counts only with proof captured at the time of the audit: cash counts and receipts, deal files with customer ID, the internal reporting log, the AML manual and training records, and the 2027 plan.
- Give every fail an owner and a fix time. Record what you saw and who owns the fix. Each standard carries an ideal fix time, from immediate to 30 days, counted from audit submission (see the table above).
- Fix it, then prove it. The site fixes the cause and uploads proof of closure; the auditor checks the proof before closing the finding.
- Re-check at the next audit. Confirm closed findings stay closed, and look for the same fail at your other sites so one gap doesn't repeat across the network.
Who this guidebook is for
- Management: answers with its own assets
- Cashiers and sales staff: know when to say no
- Auditors: review cash counts and deal files
A reference document, not legal advice. Fines and rules change: check the current text with the regulator or your legal adviser before acting.
