Banking restrictions to prevent money laundering

21/10/2025

In June 2025 the Banco de España and Sepblac updated their recommendations for banks when they have a legal obligation to freeze accounts or terminate ––or refrain from entering into− relationships with certain customers, to prevent money laundering or terrorist financing.

These best practices seek to ensure that such measures are warranted, transparent and respectful of customers’ rights, to avoid excluding them from the financial system on insufficient grounds.

Here’s what’s new:

• Banks must act proportionately, depending on the type of customer, product or financial transaction. In other words, they can’t close accounts or deny banking services to entire groups without analysing the real risk presented by each individual customer.
• When banks have to decide whether or not to enter into a business relationship with a potential customer, they need to strike a balance between their duty to prevent money laundering and not excluding people from the financial system.
• A request to open an account from a vulnerable individual can only be refused if there’s a clear money laundering risk or where the necessary control measures can’t be implemented.
• If a bank decides not to open an account, close an existing one or refuse a transaction to prevent money laundering, it must record the decision internally and explain why it was taken. It’s considered good practice for banks to keep separate lists based on the reasons for refusal, indicating if these were business-related or on anti-money laundering grounds.
• Banks must notify their customers when their accounts are blocked or services restricted as agreed in the contract. But, given that these measures have severe consequences for customers, banks should observe the following guidelines: (i) in the case of notifications via the online banking mailbox, they must be proactive and send the customer an email or an SMS; (ii) if there are several account holders, they must all be notified.
• When a bank tells a customer that it’s terminating the relationship, it must inform them of their right to lodge a complaint with the customer service department and, if they don’t receive a satisfactory reply, with the Banco de España.