PG-010 · Implementation Guide

    Building an AML Framework in One Week

    Agency owners, lawyers, property developers7 min readVersion 1.0Updated June 2026

    Why this matters

    Many real estate businesses know they are obligated subjects, but lack a structured framework. Building one from scratch feels overwhelming.

    In practice, with the right combination of expertise and software, an operational AML framework can be in place within a single working week.

    Practical implementation

    Day 1 — Diagnostic

    CostaAML Compliance reviews the current state: business model, risk exposure, existing documentation and gaps.

    Day 2 — Policies and procedures

    Draft tailored AML policies, risk methodology, EDD criteria and internal roles.

    Day 3 — Platform setup

    Configure PropComply: onboarding flows, risk model, screening, document templates and access control.

    Day 4 — Training

    Train the team on both the policies and the operational workflows in PropComply.

    Day 5 — Go-live

    Start onboarding new clients through the framework, with CostaAML Compliance on standby for support.

    How PropComply helps

    • Pre-built workflows aligned to Spanish real estate scenarios.
    • Configurable risk model and EDD criteria.
    • Centralised client files and audit trail from day one.
    • Designed to be operational on day five — not month six.

    PropComply supports — but does not replace — professional judgement, and does not guarantee AML compliance. Each obligated subject remains responsible for its own AML decisions.

    Practical example

    A boutique agency goes from no framework to operational AML

    A Marbella boutique agency without a formal AML framework engages CostaAML Compliance and adopts PropComply.

    Within five working days, policies are in place, PropComply is configured, the team is trained, and the first clients are onboarded through the new framework.

    Two weeks later, every active client file follows the same structured process.

    Best practice

    • ·Combine advisory and technology — neither alone is enough.
    • ·Focus on operational adoption, not just documentation.
    • ·Use the first weeks to refine the framework based on real client cases.

    Need help implementing your AML framework?

    CostaAML Compliance provides AML implementation, training, documentation and regulatory support for Spanish real estate professionals.

    Learn about CostaAML Compliance

    Need an operational AML platform?

    PropComply helps digitise customer due diligence, onboarding and AML documentation for Spanish real estate.

    Book a PropComply Demo