AML & KYC glossary

Short, plain-language definitions of the terms that appear in Spanish and Portuguese real estate compliance. For fuller explanations see the AML & KYC Guide.

Adverse media: Negative news or public-record information about a client that may indicate financial crime risk. Reviewed as part of enhanced due diligence.
AML: Anti-money laundering: the framework of laws, controls and procedures preventing criminal proceeds entering the legitimate economy. Read more
AMLA: The EU Anti-Money Laundering Authority, created under the EU AML Package to supervise and coordinate AML across member states.
Beneficial owner (UBO): The natural person who ultimately owns or controls a client or on whose behalf a transaction is conducted, commonly assessed from a 25% ownership or control threshold.
BOE: Boletín Oficial del Estado — the Spanish official gazette where Ley 10/2010 and Real Decreto 304/2014 are published.
CDD: Customer due diligence: the legally required measures to identify, verify, understand and monitor a client. Read more
Client onboarding: The end-to-end process of taking a new client from first contact to an approved, documented file. Read more
DNI: Documento Nacional de Identidad — the Spanish national identity document.
EDD: Enhanced due diligence: intensified measures applied where higher risk is identified. Read more
FIU: Financial intelligence unit — the national body receiving suspicious activity reports. SEPBLAC in Spain, UIF in Portugal.
GDPR: EU General Data Protection Regulation, which governs lawful basis, minimisation, retention and the rights of clients whose data is processed for AML purposes.
High-risk third country: A jurisdiction identified by the EU as having strategic AML deficiencies; connections to it trigger enhanced due diligence.
KYC: Know Your Customer: identifying, verifying and risk-assessing a client before and during a business relationship. Read more
Lei 83/2017: The Portuguese anti-money-laundering law setting out the obligations of entidades obrigadas, including real estate professionals.
Ley 10/2010: The Spanish law on prevention of money laundering and terrorist financing, which makes real estate agents obliged subjects. Read more
NIE: Número de Identidad de Extranjero — the Spanish identification number required by foreign buyers to complete a property purchase.
Obliged subject: Sujeto obligado: a business legally required to apply AML measures, including real estate agents, lawyers, notaries and developers.
Ongoing monitoring: Keeping client data, screening and risk classification current for the duration of the relationship.
PEP: Politically exposed person: an individual holding a prominent public function, plus their family members and close associates. Read more
Real Decreto 304/2014: The Spanish regulation developing Ley 10/2010, setting out detailed due diligence, recordkeeping and internal control requirements.
Registro Mercantil: The Spanish commercial registry, used to verify company existence, directors and ownership.
Risk-based approach: The principle that the intensity of AML measures must be proportional to the assessed risk, and that the assessment must be documented.
Sanctions screening: Checking clients and counterparties against official sanctions and watchlists; an absolute prohibition rather than a risk-based judgement. Read more
SDD: Simplified due diligence: reduced measures permitted where lower risk is demonstrable and documented. Never an exemption.
SEPBLAC: Spain's financial intelligence unit and AML supervisory authority, which receives suspicious activity reports and conducts supervision.
Source of funds: The specific origin of the money used in a transaction, evidenced proportionally to risk. Read more
Source of wealth: How a client's overall assets were accumulated, as distinct from the funds used in a single transaction.
SAR / comunicación por indicio: A report made to the financial intelligence unit where there is suspicion of money laundering or terrorist financing.
Tipping off: Informing a client that a suspicious activity report has been or may be made — prohibited under AML law.
Titularidad real: The Spanish term for beneficial ownership, evidenced through registry data or a notarial declaration.