PG-004 · Implementation Guide

    PEP & Sanctions Screening Workflow

    Real estate agents, lawyers, mortgage brokers7 min readVersion 1.0Updated June 2026

    Why this matters

    Screening is a regulatory expectation, not a nice-to-have. Missing a sanctioned party in a transaction can expose the business to severe regulatory and reputational consequences.

    Screening once at onboarding is not enough — clients and sanctions lists change over time.

    Practical implementation

    Initial screening

    Screen the client, all beneficial owners and relevant connected parties at onboarding against PEP, sanctions and adverse media data.

    Match handling

    Investigate alerts using structured criteria — name, date of birth, jurisdiction and role — to confirm true matches and discard false positives.

    Ongoing screening

    Re-screen the client base regularly so newly-listed parties are detected without manual effort.

    How PropComply helps

    • Integrated PEP, sanctions and adverse media screening from trusted data sources.
    • Guided alert resolution with structured decision rationale.
    • Continuous monitoring of existing client files — not just a snapshot at onboarding.
    • Audit trail of every match, decision and override.

    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

    An adverse media hit on a corporate director

    PropComply flags adverse media on a director of a buying company linked to a fraud investigation abroad.

    The compliance officer reviews the source, confirms it relates to the same individual, and decides to apply Enhanced Due Diligence with additional source of wealth review.

    The decision and supporting evidence are stored in the audit trail.

    Best practice

    • ·Document why a match is discarded, not only why it is accepted.
    • ·Ensure screening covers all relevant parties — not just the named client.
    • ·Re-screen at meaningful intervals appropriate to client risk.

    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?

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