From Client Enquiry to AML Compliance
Why this matters
Most AML failures in Spanish real estate happen during onboarding — paperwork is missing, identity checks are inconsistent, and information sits in emails or WhatsApp instead of a structured file.
When SEPBLAC inspects, they look at how the obligated subject moved from enquiry to a signed contract — and whether due diligence was completed before risk was accepted.
Practical implementation
1. First contact
Log the enquiry, capture the client's intent (buy, sell, rent, invest), and identify which legal entity or natural person you are dealing with.
2. Identification
Collect identity documents, address verification and — for legal entities — corporate documentation and beneficial ownership information.
3. Screening
Perform PEP, sanctions and adverse media screening on all relevant parties, including beneficial owners.
4. Risk classification
Assign a risk rating based on client type, geography, transaction profile and screening results.
5. CDD or EDD decision
Apply standard CDD for low and medium risk, or escalate to Enhanced Due Diligence for high-risk clients.
6. File completion
Document all decisions, store evidence, and only then proceed with the commercial relationship.
How PropComply helps
- Guided onboarding flow that captures the same information consistently for every client.
- Automatic PEP and sanctions screening, with structured handling of true matches versus false positives.
- Risk classification that combines client, geography and transaction signals.
- Timestamped audit trail of every decision, so the file is inspection-ready.
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 foreign buyer enquires about a Marbella villa
A non-resident buyer contacts a Marbella estate agent about a €1.8M villa. The agent sends a PropComply onboarding link to the buyer's email.
The buyer uploads passport, proof of address and source-of-funds documentation. PropComply screens for PEP and sanctions, flags a politically exposed family member, and the agent escalates the file to Enhanced Due Diligence.
Within 48 hours, the file is complete, risk-rated and ready to be shared with the lawyer handling the transaction — without any documents leaving secure storage.
Best practice
- ·Never begin substantive commercial work before identity has been verified.
- ·Treat onboarding as one continuous workflow, not separate email threads.
- ·Use a single source of truth for the client file — not personal inboxes.
- ·Re-verify identity and risk at key trigger events, not only at onboarding.
Frequently asked questions
When does the AML obligation begin?
AML obligations begin as soon as a business relationship is being established — not only when a contract is signed. Information gathered during the enquiry stage already forms part of the AML file.
Can the lawyer's KYC replace the agent's KYC?
No. Each obligated subject must perform its own customer due diligence. PropComply allows the same client file to be shared, but each party remains responsible for its own AML assessment.
Related guides
How PropComply Performs Customer Due Diligence
The complete KYC and CDD workflow supported by PropComply — identification, verification, screening and documentation.
Real Estate AML Risk Assessment
How client risk scoring and transaction risk assessment work inside PropComply.
PEP & Sanctions Screening Workflow
How PEP, sanctions and adverse media screening is integrated into onboarding — and why ongoing screening matters.
Need help implementing your AML framework?
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