KYC/CDD for Lawyers in Spanish Real Estate
Inherit the agent's structured file. Run your independent AML assessment on top.
Lawyers acting in Spanish real estate transactions are obliged subjects under Ley 10/2010 and must perform their own independent customer due diligence — even when the agent has already done so. PropComply lets lawyers inherit the agent's structured KYC/CDD file to skip duplicate data collection, then layer their own independent assessment, Enhanced Due Diligence and documentation on top, with an audit trail ready for SEPBLAC and bar inspections.
Common Challenges
- Duplicate work collecting documents the agent already has
- Inconsistent file formats from different agents
- Need for audit-ready, defensible files
- Enhanced Due Diligence for high-risk or PEP clients
- Secure collaboration without compromising independence
How PropComply Helps
- Inherit verified KYC/CDD from the agent — no re-collection
- Independent AML assessment layer preserved
- Ley 10/2010 and RD 304/2014 aligned CDD and EDD workflows
- PEP, sanctions, watchlist and adverse media screening
- Permission-based sharing with notaries, banks and developers
- Audit trail ready for SEPBLAC and bar inspections
Step-by-step for lawyers
- 1
Receive the file
Accept a permission-based, time-limited share of the client's KYC/CDD file from the agent.
- 2
Independent review
Run your own CDD: review identity, beneficial ownership, source of funds, screening hits and risk factors.
- 3
Apply EDD if needed
Trigger Enhanced Due Diligence for PEPs, high-risk jurisdictions or complex structures, with structured documentation.
- 4
Document your decision
Record your independent risk classification, mitigation steps and rationale — timestamped in the audit trail.
- 5
Share or escalate
Share the file forward to notary or bank as needed; escalate suspicious activity to SEPBLAC where required.
Frequently Asked Questions
Do lawyers in Spain have their own AML obligations under Ley 10/2010?
Yes. Lawyers participating in real estate transactions — including buying, selling or managing property — are obliged subjects under Ley 10/2010. They must perform their own CDD, keep records and report suspicious activity. Receiving a KYC file from the agent does not transfer or replace those obligations.
Can a lawyer rely on KYC done by the agent?
Lawyers can use structured information shared by the agent as a starting point, but must perform their own independent AML assessment. PropComply is designed for this: the lawyer inherits the structured file, then layers an independent review, EDD and decision on top.
How does PropComply support Enhanced Due Diligence?
PropComply flags PEPs, sanctions hits, high-risk jurisdictions and complex ownership structures, and guides the lawyer through documenting EDD measures — including source-of-wealth verification, senior approval and ongoing monitoring decisions.
Is PropComply a law firm or legal advice provider?
No. PropComply is a software solution that supports KYC/CDD and AML workflows. It does not provide legal advice and does not replace the lawyer's independent professional responsibility.
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