National Risk Assesment 2026

Based on the obligation to conduct a national risk assessment regarding Money Laundering and Terrorist Financing set forth in (EU) 2015/849, and the need to focus countermeasures on the identified risks, Spain conducted its first NRA in 2020, which was only partially updated in 2024.

In this context, this NRA constitutes a comprehensive and complete assessment of the ML/TF risks affecting all obliged entities covered by Law 10/2010 of April 28, which is the Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT) law. Unlike the previous exercise, focused on partial or sector-specific updates—since the preliminary analysis indicated that there were no changes in the remaining risks— this analysis comprehensively addresses the threats, vulnerabilities, and risks associated with all sectors subject to preventive obligations, taking into account the evolution of criminal patterns, national and international regulatory changes, the impact of the digitization of financial services, and the growing complexity of the structures and methods used to channel illicit funds. From a methodological standpoint, while it builds on previous analyses, it seeks to strengthen the quantitative basis of the analysis and simplify it to ensure a better understanding of the risks.

Since 2020, events such as the COVID-19 pandemic, the war between Russia and Ukraine, the Israeli-Palestinian conflict, the increase in risks associated with international financial sanctions, the expansion of crypto-asset service providers (CASPs), the development of new Fintech solutions, and the growing use of advanced technological tools in the financial sector have created new challenges for authorities, institutions, and obliged entities. At the same time, criminal organizations and Terrorist Financing networks have evolved their methods and operational mechanisms, exploiting vulnerabilities stemming from financial globalization, the international interconnection of markets, and rapid technological innovation.

All of this requires a continuous update of the mechanisms for identifying, assessing, and understanding risks, enabling competent authorities and obliged entities to adapt their preventive systems to new crime patterns, modes of operation, and emerging risk factors.

This document was approved by the COPBLAC at its meeting on June 12, 2026.

This public version of the 2026 NRA serves to share the analysis conducted with the private sector: National Risk Assessment