Investment approach
Payments and Client Checks for Investors from Russia and the CIS
Banks and notaries in Spain check who the client is and who stands behind them, where the money comes from and whether EU sanctions apply. The article describes the checkers' duties, not ways to pass.
Banks and notaries in Spain check a chain of three questions: who the client and the ultimate owner are, where the money comes from, and whether EU sanctions affect anyone in the deal. Client verification (customer due diligence) is a duty of banks, notaries, lawyers and agencies under Ley 10/2010: establish identity, find out the purpose of the transaction and the source of funds. EU sanctions operate separately and directly: the Union's measures bind any person from the moment of listing (art. 42 of Ley 10/2010). The article describes the checks: it contains no advice on how to get around them and no assessments of specific people.
What do banks and notaries check by law?
The texts were checked against the consolidated BOE version of 13.10.2026.
| Check | Basis | What it means in practice |
|---|---|---|
| Identity | art. 3 of Ley 10/2010 | An identity document before the relationship starts; anonymous and numbered accounts are prohibited |
| Ultimate owner | art. 4 | Natural persons with a stake or votes above 25%; if the structure cannot be determined, the relationship is not opened |
| Purpose and nature of the relationship | art. 5 | Documents on the stated activity or information from independent sources |
| Source of funds and monitoring | art. 6 | Transactions are checked against the client's profile also after the account is opened |
| Politically exposed persons | art. 14 | Enhanced measures for those who hold or have held a public office |
| Non-face-to-face relationship | art. 12 | Allowed only on the terms of the law; the bank receives copies of the documents within a month, and if the data do not match, in-person identification is needed |
| Method of payment in the deed | art. 24 of the Ley del Notariado (notarial law) | The notary records the price, the amount, the method and the time of payment in the escritura (deed of sale) |
| Sanctions measures | art. 42 of Ley 10/2010 | EU measures are binding immediately upon listing; the bank must have procedures against the risk of circumvention (art. 42.5) |
The law has no list of documents; the bank sets the scope by risk assessment (art. 7). The overall picture is covered in the article on AML when buying.
How does the sanctions circuit work?
First of all, it looks at the persons on the list. Regulation (EU) 269/2014 requires freezing all funds and economic resources that belong to listed persons, are held by them or are under their control, and prohibits making funds available to them directly or indirectly (art. 2, text in the original wording of 17.03.2014). The regulation counts real estate among economic resources (art. 1.d). Knowingly participating in activities whose object or effect is to circumvent the prohibition is also prohibited (art. 9).
That is why the bank screens the buyer, as well as the owners and controlling persons of a buying company, the payer and the seller. The list of persons is maintained by the European Commission (consolidated list), and it changes: the European Commission page notes an update on 12 October 2026, a listing package against Russia. Measures are adopted separately by country and by person, so a conclusion for one country cannot be carried over to another.
Separately, Regulation (EU) 833/2014 applies: it contains restrictions for banks and other operators, some of which are tied to the client's nationality, residence or place of establishment. The bank applies it in the current wording published on EUR-Lex; I will not retell its terms here, because I could not open the current consolidated text as of the date of the article.
Why can a payment be delayed or not executed?
The reasons follow from the law. The payer does not match the buyer: the bank must find out on whose behalf the client acts (art. 4.3). The documents do not fit the stated activity (art. 5). The transaction is complex or has no obvious economic purpose: then the bank carries out an examen especial (special review) (art. 17) and, if there is suspicion, reports to the Servicio Ejecutivo (Sepblac) and, as a rule, refrains from executing it (arts. 18–19). A notary may refuse where there are several risk indicators or an evident sham transaction (art. 19.2).
The bank may not explain the reason: the law prohibits telling the client that a transaction is being examined or has been reported (art. 24).
Cash payments are limited by art. 7 of Ley 7/2012, and under art. 24 of the Ley del Notariado the notary records in the escritura the method, amount and time of each payment of the price.
What does the chain look like in round numbers?
A worked example, not a forecast and not an assessment of specific people. The buyer, an SL (Spanish limited company), is owned by A at 70% and by B at 30%. Price 2 M€. The 10% deposit (200 000 €) arrives from A's account at an EU bank, the balance of 1.8 M€ from A's account at a bank outside the EU.
The questions will be these. Who is the ultimate owner? Both stakes are above 25%, so both A and B are checked. Where does the money come from and what confirms it? Is the payer someone who appears in the structure? Do the names and amounts in the transfers match the escritura?
Who is this analysis not for?
Anyone looking for a way to pass the check: the article is about what is checked, not how to get around it. Anyone who is on a sanctions list, or whose company is, or is controlled by such a person: that is a question for a sanctions lawyer before any action. And anyone expecting an assessment of their case: an abogado (lawyer) gives it, and the lists and acts change, so the check has to be made as of the date of the deal. From 2027 the single EU anti-money-laundering regulation 2024/1624 starts to apply (European Commission).
On documents and timing: moving capital to Spain and international transfers.
Questions and answers
Is a purchase refused solely because of Russian citizenship?
Ley 10/2010 builds the check on identity, structure and source of funds. EU sanctions regulations, including 833/2014, also contain restrictions tied to citizenship or residence. How they apply to a specific person as of the date of the deal is assessed by an abogado on the current text in EUR-Lex.
Which documents confirm the source of funds?
The law gives no list: it speaks of documents on the stated activity or information from independent sources (art. 5). Which ones the bank accepts, it decides itself by risk level.
Why does the bank not explain the reason for a refusal or delay?
The law prohibits it from telling the client that a transaction is being examined or has been reported (art. 24 of Ley 10/2010). The bank's silence proves nothing.
What changes from 2027?
EU regulation 2024/1624 on combating money laundering starts to apply. I did not analyse its requirements for a property buyer.
