Enhanced Due Diligence (EDD) Workflow
A structured EDD workflow for high-risk clients, PEPs and complex ownership structures.
PropComply provides a structured Enhanced Due Diligence (EDD) workflow for high-risk clients, politically exposed persons and complex beneficial-ownership structures involved in Spanish real estate transactions. The workflow captures the additional evidence, senior-management approval and ongoing-monitoring decisions required under Articles 11 and 19 of Ley 10/2010.
Capabilities
- EDD triggered automatically by risk classification or PEP status
- Deeper source-of-funds and source-of-wealth evidence
- Beneficial-ownership reconstruction for layered entities
- Senior-management approval flow with audit trail
- Enhanced ongoing monitoring frequency
Outcomes
- Defensible EDD files for SEPBLAC inspection
- Clear separation of standard and enhanced CDD
- Documented senior-management approvals
- Repeatable EDD process across the firm
Step-by-step
- 1
Trigger EDD
EDD is triggered automatically based on risk classification, PEP status or complex ownership.
- 2
Collect enhanced evidence
Additional SoF/SoW evidence and ownership reconstruction are collected through a guided workflow.
- 3
Senior-management approval
The file is routed to a senior decision-maker for documented approval before the relationship proceeds.
- 4
Enhanced ongoing monitoring
The relationship is monitored at a higher frequency, with screening and review intervals tightened.
Frequently Asked Questions
When is EDD required under Ley 10/2010?
Articles 11 and 19 of Ley 10/2010 require enhanced due diligence for high-risk situations, including PEPs, high-risk third countries and complex or unusual transactions with no apparent economic purpose.
Does PropComply require senior-management approval for EDD?
Yes. The EDD workflow includes a documented senior-management approval step before the relationship is established or continued.
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