Client checks and source of funds

Why it is needed

Companies involved in property transactions in Spain are required to verify their clients under the anti-money-laundering law (Law 10/2010). This is not a DNPI formality: the bank that processes the payments and the notary at signing will ask the same questions later. If the documents are gathered once and in good order, the transaction moves faster.

The money stays with the client: every project payment comes from the client's own account. The checks establish who the client is and where those funds come from.

What is usually requested

Identity

• A valid passport.
• An NIE, if you already have one.
• Proof of address.

If a company is buying

• Incorporation documents and a registry extract.
• Details of the beneficial owners: the individuals who own or control the company.
• Documents for the directors or representatives who sign.

Source of funds for this transaction

• Statements for the account the payments will come from.
• A document explaining where the money in that account came from. For example: a contract for the sale of a property or business, tax returns showing income or dividends, inheritance or gift documents, a savings history.

Source of wealth

Enhanced checks ask more broadly how the client's wealth was built. A short description with supporting documents for the main sources is usually enough.

Public roles and sanctions

• A questionnaire on whether the client or close relatives hold public office.
• Screening against EU and Spanish sanctions lists.

When checks are enhanced

The law requires deeper checks, for example, if the client is connected to a country the EU classes as high risk, holds public office, or has a complex source of funds. There are then more documents and questions, and the process takes longer. In some cases EU sanctions law does not allow the transaction; this is established before any work starts.

How to prepare

• Put the documents together in one package early, even before choosing a property.
• Documents not in Spanish or English may need translating.
• Check that the amount and the route of the money to the Spanish account are explained by documents, with no gaps.
• Before the first payment, ask your bank about its own requirements.

How we store the data

Verification documents are kept for the period the law requires and processed under our privacy policy. They are used only for the checks and are not shared with third parties except where the law requires.

The full process is on How we work with investors.