Customer Due Diligence (CDD)
Identification, UBO, risk classification and ongoing monitoring
Client identification
Verify the identity of every client using reliable, independent documentation before establishing the business relationship. For natural persons: passport or DNI/NIE. For legal entities: incorporation documents, ownership chart, UBO declaration.
Beneficial ownership
Identify and verify the natural person who ultimately owns or controls the client. Spanish law generally considers any individual holding more than 25% ownership or voting rights as a UBO.
Risk classification
Classify each client as Low, Medium or High risk based on jurisdiction, transaction profile, source of funds and PEP/sanctions exposure. The classification drives the depth of due diligence applied.
Enhanced Due Diligence (EDD)
EDD is required for high-risk clients, PEPs and high-risk jurisdictions. It includes additional source-of-funds documentation, senior management approval and enhanced ongoing monitoring.
Ongoing monitoring
CDD does not stop at onboarding. Monitor the relationship for changes in ownership, transaction patterns or risk profile, and refresh documentation periodically.
Official sources for this module
Primary publications from SEPBLAC and the Spanish Tesoro underpinning the material above.
- SEPBLACPDFGuía orientativa sobre riesgo geográfico
SEPBLAC guidance on assessing geographic risk — feeds directly into client risk classification.
See the full list on the Sources page.