Enhanced Due Diligence in Practice
Why this matters
Standard CDD is not enough for high-risk clients — politically exposed persons, complex offshore structures, high-value cash-heavy transactions or clients from high-risk jurisdictions.
Failure to apply EDD when triggered is one of the most cited weaknesses in real estate AML inspections.
Practical implementation
Identify EDD triggers
PEP status, high-risk jurisdiction, unusual transaction structure, opaque ownership, large cash component or adverse media.
Apply additional measures
Senior management approval, deeper source of funds and source of wealth analysis, additional identity verification and ongoing enhanced monitoring.
Document the rationale
Every EDD decision must be justified, evidenced and timestamped — not only the outcome.
How PropComply helps
- Automatic escalation from standard CDD to EDD when risk triggers are detected.
- Dedicated EDD checklist tailored to Spanish real estate transactions.
- Structured capture of senior management approvals.
- Full audit trail of additional measures applied.
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 PEP-related buyer from a high-risk jurisdiction
A buyer indirectly connected to a foreign PEP wants to acquire a €4M property through a Gibraltar company.
PropComply flags both the PEP exposure and the offshore structure, automatically escalating the file to EDD.
The compliance officer reviews source of wealth, requests additional documentation, and records senior management approval before the transaction proceeds.
Best practice
- ·Define your EDD triggers in writing and apply them consistently.
- ·Treat EDD as a process, not a one-off form.
- ·Engage CostaAML Compliance for second-line review on the most sensitive files.
Related guides
How PropComply Performs Customer Due Diligence
The complete KYC and CDD workflow supported by PropComply — identification, verification, screening and documentation.
Source of Funds & Source of Wealth Workflow
How supporting documentation should be collected, reviewed and documented for property transactions.
PEP & Sanctions Screening Workflow
How PEP, sanctions and adverse media screening is integrated into onboarding — and why ongoing screening matters.
Real Estate AML Risk Assessment
How client risk scoring and transaction risk assessment work inside PropComply.
Need help implementing your AML framework?
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