Beneficial Ownership Verification
Why this matters
Property is frequently used to hold or move value through corporate structures. Without identifying the real human beneficiaries, AML controls fail at the most important point.
Spanish AML regulation requires obligated subjects to identify and verify the ultimate beneficial owner — not only the named client.
Practical implementation
Ownership chain
Map the full ownership structure — every shareholding entity between the client and the ultimate natural person owners.
Threshold
Apply the 25% ownership or control threshold, while remaining alert to control exercised through other means.
Verification
Verify the identity of each beneficial owner using independent documents — not only declarations.
Trusts and foundations
Identify settlors, trustees, protectors and beneficiaries, applying additional scrutiny where structures lack transparency.
How PropComply helps
- Guided capture of ownership chains for legal entities.
- Identification and screening of each beneficial owner.
- Storage of corporate documents, shareholder registers and ownership declarations in one structured file.
- Clear visualisation of the structure for inspection readiness.
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 two-layer corporate buyer
A Spanish SL is 100% owned by a Luxembourg holding company, which in turn is owned 60/40 by two individuals.
PropComply captures the full chain, identifies both individuals as ultimate beneficial owners, screens them, and stores supporting corporate documents.
The file clearly shows who ultimately benefits from the transaction.
Best practice
- ·Never rely on a single declaration form as proof of beneficial ownership.
- ·Re-verify beneficial ownership at trigger events such as restructuring.
- ·Engage CostaAML Compliance for complex international structures.
Related guides
How PropComply Performs Customer Due Diligence
The complete KYC and CDD workflow supported by PropComply — identification, verification, screening and documentation.
Enhanced Due Diligence in Practice
How higher-risk clients should be handled and how PropComply supports Enhanced Due Diligence in real estate transactions.
AML File Management & Record Keeping
How AML documentation should be organised, stored and retained across the client lifecycle.
Need help implementing your AML framework?
CostaAML Compliance provides AML implementation, training, documentation and regulatory support for Spanish real estate professionals.
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