Secure KYC/CDD File Sharing Between Parties
One client — one KYC file — shared securely between every party in the transaction.
PropComply's secure-sharing module lets the obliged subjects in a Spanish real estate transaction share a single, standardised KYC/CDD file — instead of every party re-collecting documents from the client. Sharing is consent-based, scoped to the specific transaction, fully audited, and aligned with Ley 10/2010 and GDPR. Each obliged subject retains independent AML responsibility on the shared file.
Capabilities
- Granular permissions per recipient and per document
- Client consent capture for each sharing event
- Time-limited and transaction-scoped access
- Standardised file format readable by every party
- Full audit trail of who accessed what and when
Outcomes
- The client onboards once, not five times
- Faster transactions with fewer document requests
- Higher data quality across the deal
- Reduced GDPR exposure from email attachments
Step-by-step
- 1
Originate the file
The originating party — typically the agent or lawyer — creates the KYC/CDD file with the client.
- 2
Capture sharing consent
The client gives scoped consent to share the file with named recipients for the specific transaction.
- 3
Share with the next party
Recipients receive scoped, time-limited access to the standardised file directly in PropComply.
- 4
Independent re-assessment
Each recipient performs their own risk assessment on the shared file and retains independent AML responsibility.
Frequently Asked Questions
Is KYC sharing legal under Ley 10/2010 and GDPR?
Yes. Article 8 of Ley 10/2010 allows obliged subjects to rely on CDD performed by other obliged subjects under defined conditions, while GDPR is satisfied through explicit client consent, purpose limitation and data minimisation. Each obliged subject retains independent AML liability.
Does sharing remove my AML responsibility?
No. Each obliged subject in the transaction retains independent AML responsibility for the CDD it relies on, even when the file was originated by another party.
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