AML File Management & Record Keeping
Why this matters
Spanish AML rules require records to be retained for at least 10 years. Scattered records across email, drives and personal devices create real regulatory and GDPR risk.
When inspectors arrive, files must be retrievable quickly and in a complete, coherent form.
Practical implementation
Single client file
Maintain one structured file per client containing identification, screening, risk decisions, EDD measures and transaction documentation.
Versioning
Capture every change to the file with a timestamp and the user responsible.
Retention
Apply consistent retention periods aligned to Spanish AML law and GDPR principles.
Access control
Limit access to those who need it, with role-based permissions.
How PropComply helps
- Centralised, structured client files with full audit history.
- Role-based access control and EU data residency.
- Inspection-ready export of the complete client file in seconds.
- Retention and access policies aligned with Spanish AML and GDPR requirements.
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
Producing a file for inspection
An inspector requests the complete AML file for a transaction from 2024.
Inside PropComply, the user retrieves the client profile, exports a structured PDF including all CDD evidence, screening history, risk decisions and the full audit trail.
The file is produced in minutes — not days of email archaeology.
Best practice
- ·Do not store AML evidence in personal inboxes or messaging apps.
- ·Apply consistent file structure across all clients.
- ·Train staff that the file is the legal record — not the email thread.
Related guides
Preparing for a SEPBLAC Inspection
How organised digital AML records help real estate businesses prepare for and respond to regulatory inspections.
How PropComply Performs Customer Due Diligence
The complete KYC and CDD workflow supported by PropComply — identification, verification, screening and documentation.
Beneficial Ownership Verification
Identifying the natural persons behind companies, trusts and legal entities involved in real estate transactions.
Need help implementing your AML framework?
CostaAML Compliance provides AML implementation, training, documentation and regulatory support for Spanish real estate professionals.
Learn about CostaAML ComplianceNeed an operational AML platform?
PropComply helps digitise customer due diligence, onboarding and AML documentation for Spanish real estate.
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