Preparing for a SEPBLAC Inspection
Why this matters
SEPBLAC inspections focus on whether AML obligations have been implemented in practice — not just documented in a policy.
Most inspection findings relate to evidence: missing documents, undocumented decisions, inconsistent files.
Practical implementation
Policies and procedures
Maintain up-to-date written AML policies and procedures — typically developed with specialist support such as CostaAML Compliance.
Operational evidence
Show that the policies are applied: every client file should evidence identification, screening, risk rating, EDD where relevant and ongoing monitoring.
Training
Maintain records of staff AML training and competency.
Self-assessment
Perform internal reviews so weaknesses are corrected before regulators find them.
How PropComply helps
- Every client decision is timestamped and traceable.
- Full client files can be produced on demand.
- Management dashboards highlight gaps such as overdue refreshes or unresolved screening alerts.
- Inspection-ready exports support fast, professional responses.
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 real estate agency receives notice of inspection
An agency is notified of a SEPBLAC inspection covering the last 24 months.
Using PropComply, the compliance officer pulls a list of all clients in scope, identifies any files with gaps, and runs targeted remediation before the inspection visit.
On the day, files are produced from the platform with full audit trails — and the agency can demonstrate operational AML compliance, not just paper policies.
Best practice
- ·Treat inspection readiness as an everyday discipline, not a one-off project.
- ·Use internal reviews to test the file quality, not only the policy.
- ·Combine CostaAML Compliance advisory with PropComply operational evidence.
Related guides
AML File Management & Record Keeping
How AML documentation should be organised, stored and retained across the client lifecycle.
Real Estate AML Risk Assessment
How client risk scoring and transaction risk assessment work inside PropComply.
Building an AML Framework in One Week
How CostaAML Compliance and PropComply work together to implement an operational AML framework — fast.
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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