Spain Lottery Audit Finds €14.8M in Payouts With Missing Bank Records

Most of the older problems have been fixed. The latest Tribunal de Cuentas report records substantial progress on 28 of 30 recommendations from its previous review. The argument over bank reversals is among the issues still open.

341 Payment Files Had No Supporting Records

The disputed payments were made between 2023 and 2025. SELAE’s banks handled 168,449 major-prize payment files during those three years, worth more than €6.86 billion.

By June 18, 2026, documentation was still missing from some of those files:

• 341 payments worth €5.74 million – no supporting records received;
• 178 payments worth €9.05 million – documentation received but incomplete;
• 519 payments worth €14.79 million – total affected by the findings.

There has been a sharp reduction since the earlier audit. For payments made from 2019 to 2022, auditors counted 15,852 files with missing or incomplete records, representing €759 million.

The affected share fell from 7.84% to 0.31% of payment files. Measured by value, the decline was from 8.18% to 0.22%.

SELAE Identified Four Potentially Invalid Payments

SELAE has declined to use a contractual provision allowing it to seek reversals from banks over missing payment records. It says the measure should apply when a prize may have been paid incorrectly.

The operator identified only four cases with circumstances that could invalidate a payment. For the remaining files, it maintains that the recipients were generally identified correctly.

The Tribunal de Cuentas wants the contractual provision applied to all payments lacking the required evidence. Banks must provide records supporting the prize and the recipient’s identity before SELAE can accept the payment under its agreements.

The auditors also challenged SELAE’s reliance on earlier legal proceedings, which were closed in January 2025. Those proceedings concerned the 2019-2022 audit period. The 519 outstanding files belong to the following three years.

About €28,500 per Affected File

The outstanding €14.79 million works out to approximately €28,500 per file. That average covers both cases with no documentation and those where banks supplied only part of the required records.

Under SELAE’s published instructions, retail lottery prizes of €2,000 or more are collected through authorised financial institutions. The banks handle recipient identification and the checks required under anti-money laundering rules.

SELAE has made changes elsewhere in its AML operation. Its specialist unit now has three technical staff and one administrative employee. The operator has also shortened the time between deciding to notify Spain’s financial intelligence unit, SEPBLAC, and sending that notification.

The Tribunal’s July assessment left one recommendation partially implemented and one unimplemented. The latter concerns SELAE’s failure to seek reversals for insufficiently documented bank payments.