Spain Plans Bank and Gambling Levy to Fund New Anti-Money Laundering Agency

• Madrid proposes a new funding model for ANIFI as it overhauls the country’s system for tackling money laundering and terrorist financing.

Abstract

Spain plans to make banks, gambling companies and other regulated businesses help fund a new national agency responsible for fighting money laundering and terrorist financing. The proposed levy is part of a wider overhaul of Spain’s financial crime system and would give the new agency, ANIFI, a more independent source of funding. For businesses, the change could mean an additional regulatory cost. For authorities, it is an attempt to build a stronger institution that can keep pace with increasingly complex financial crime.

Analysis

Spain’s government has approved a draft law that would establish the National Financial Integrity Authority, ANIFI, as the country’s new central authority for tackling money laundering, terrorist financing and related financial crime.

The proposed agency would bring together functions currently carried out by Spain’s financial intelligence unit, SEPBLAC, and the Secretariat of the Commission for the Prevention of Money Laundering and Monetary Offences. ANIFI would also become Spain’s main point of contact with the European Union’s Anti-Money Laundering Authority, AMLA.

Rather than relying entirely on the government budget, Spain proposes to finance ANIFI primarily through a levy on regulated businesses that require a licence or authorisation to operate. Banks, other financial institutions and gambling operators are expected to be among the main contributors.

The proposed model would also allow a limited share of fines imposed by ANIFI to be directed towards prevention, enforcement and international cooperation. However, the precise amount of the levy and how it will be calculated have yet to be determined.

The funding proposal forms part of a much broader reform. Spain intends to replace its existing AML legislation and bring its national framework into line with the EU’s 2024 anti-money laundering package.

 Compliance implications

For banks and gambling operators, the most immediate issue is the prospect of a new recurring regulatory cost.

The levy would sit alongside existing obligations to identify customers, understand ownership, monitor transactions and report suspicious activity. The proposed structure also suggests that Spain wants the businesses most exposed to financial crime risks to contribute directly to the cost of supervising the system designed to control those risks.

For compliance teams, the creation of ANIFI could also mean a more centralised approach to supervision, investigations and enforcement. The proposed authority would have responsibilities covering financial intelligence, inspections, supervision, administrative sanctions and international cooperation.

This could increase the importance of maintaining accurate customer records, effective transaction monitoring and clear evidence that compliance decisions are properly documented

Why the update matters

The significance of the Spanish proposal goes beyond the levy.

Spain is effectively redesigning the architecture through which it fights financial crime. Bringing intelligence, supervision, enforcement and international cooperation under a stronger central authority could make it easier for authorities to connect information that currently sits across different institutions.

It also reflects the wider European move towards stronger and more coordinated AML supervision following the creation of AMLA.

For banks and gambling companies, the message is equally clear. Financial crime compliance is becoming a larger regulatory responsibility, and governments are increasingly looking to the sectors exposed to these risks to help finance the systems used to manage them.

The proposal is not yet final law, and important details of the levy remain outstanding.

Compliance Takeaway

The cost of financial crime compliance is becoming part of the regulatory equation. Businesses should watch the final design of Spain’s levy closely, while preparing for a stronger supervisory environment under ANIFI.