Module

Customer Risk Classification (NRA-aligned)

Document a defensible risk-based approach for every client and every transaction.

PropComply's risk classification module assigns a documented ML/TF risk level to every client in a Spanish real estate transaction based on geography, occupation, transaction type, beneficial ownership and source-of-funds factors aligned with the Spanish National Risk Assessment. The risk level drives the depth of due diligence and whether enhanced due diligence (EDD) is required.

Capabilities

Risk model aligned with the Spanish NRA for ML/TF
Configurable risk factors per obliged subject
Automatic escalation to EDD on high-risk indicators
Versioned scoring with rationale stored on the file
Periodic re-assessment for ongoing relationships

Outcomes

Consistent risk decisions across the firm
Documented rationale for every classification
Faster decisions on low-risk clients
Inspection-ready evidence of a risk-based approach

How it works

Step-by-step

1
Capture risk factors
Risk-relevant data is collected during onboarding — nationality, residency, occupation, PEP status, transaction type and source of funds.
2
Score and classify
The client is classified low, medium or high risk using NRA-aligned weightings, with the rationale stored on the file.
3
Apply the right CDD depth
Simplified, standard or enhanced due diligence is applied automatically based on the classification.
4
Re-assess on triggers
Re-classification is triggered by new information, changes in beneficial ownership or periodic review.

FAQ

Frequently Asked Questions

What is a risk-based approach under Ley 10/2010?

Articles 7 and 17 of Ley 10/2010 require obliged subjects to apply CDD measures proportionate to the risk of money laundering or terrorist financing identified for each client and transaction.

Is the risk model auditable by SEPBLAC?

Yes. Every classification stores the inputs, weightings and rationale used, so SEPBLAC inspectors can trace why a client was classified at a given risk level.