Definition and requirements

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Those persons that, in accordance with the provisions of Law 10/2010 of 28 April on the prevention of money laundering and terrorist financing, have communicated to Sepblac their intention to act as such are considered as external experts.

External experts are intended to carry out an annual examination on the internal control measures referred to in articles 26, 26 bis and 26 ter of Law 10/2010 of 28 April adopted by obliged subjects.

The results of the examination must be documented in a written report detailing the internal control measures in place, assessing their operational efficiency and eventually proposing changes or improvements as required. However, in the two years following the issue of this report, it may be replaced by a monitoring report issued by the external expert, dealing only with the appropriateness of the measures taken by obliged subjects to remedy the deficiencies detected.


Obliged subjects must entrust the external examination to persons having the adequate academic and professional background to perform the task correctly. Consequently, it is the responsibility of obliged subjects to select adequate professionals as well as verifying that the external examination be carried out in the terms established in Order EHA/2444/2007 of 31 July.

  • Obliged subjects shall not entrust the external examination to any natural person who renders or has rendered them any other kind of paid services in the three years prior or following to the date of issue of the report.