Introduction to AML in Spain

What is AML?

Anti-Money Laundering (AML) refers to the laws, regulations and operational practices designed to prevent criminals from disguising illicit funds as legitimate income. In real estate, AML protects the integrity of the market and the reputation of professionals operating in it.

Why AML matters in real estate

Property transactions involve high-value assets, complex ownership structures and international clients — making them attractive vehicles for laundering proceeds of crime. Spanish authorities and FATF consistently identify real estate as a high-risk sector.

Overview of Ley 10/2010

Spain's Ley 10/2010 on the Prevention of Money Laundering and Terrorist Financing applies directly to real estate agents, intermediaries and developers. Obligations include:

• Customer Due Diligence (CDD) on all clients
• Identification of the Ultimate Beneficial Owner (UBO)
• Risk-based assessment of every transaction
• Recordkeeping for at least 10 years
• Internal escalation and SEPBLAC reporting of suspicious activity

The risk-based approach

Not every client poses the same risk. A risk-based approach means tailoring the depth of due diligence to the actual risk presented by the client, jurisdiction, transaction structure and source of funds.

Looking ahead: EU AMLR (Regulation 2024/1624)

From 10 July 2027, the new EU Anti-Money Laundering Regulation (AMLR) will apply directly across all Member States, replacing much of the current directive-based framework. Real estate agents, intermediaries and developers are explicitly listed as obliged entities. This training is aligned with the new regime so you are ready before it takes effect:

• Single EU-wide rulebook — directly applicable, no national transposition needed
• Mandatory UBO identification at 25% threshold (lower for higher-risk entities)
• EUR 10,000 EU-wide cash payment limit
• Stricter CDD on PEPs, third-country nationals and high-risk jurisdictions
• New EU Anti-Money Laundering Authority (AMLA) with direct supervisory powers
• Enhanced obligations for crypto-assets and high-value goods linked to property deals