Source of funds
Yes, country of origin feeds into the overall assessment as one of several risk factors — for instance where capital controls or elevated corruption risk exist there.
It is expressly only one factor among several. Drawing conclusions from nationality alone is as wrong as assuming that an EU country of origin makes any check unnecessary.
Where capital controls exist in the country of origin, the transfer route itself can additionally become a risk factor — and one that changes over time. Such rules are loosened and tightened; the current position should be checked separately in the individual case rather than assumed.
Two questions that easily run together are worth keeping apart: whether the transfer is permissible, and whether the origin of the funds is plausible. An unproblematic transfer route says nothing about where the wealth came from.
Legal basis: Ley 10/2010, Art. 6
Practical tip: A case from our own brokerage practice, still before Russia's war of aggression against Ukraine: a Ukrainian buyer held his funds in Luxembourg. The transfer itself was unproblematic — Luxembourg was subject to no capital controls — and the origin of those funds still had to be carefully traced. That separation is exactly the point.
AI-assisted tools were used in preparing these FAQs; the content was subsequently reviewed and approved by the Doxario editorial team. They reflect the general state of the law as at the review date shown and do not constitute individual legal or tax advice. To assess your own case — particularly where complex structures are involved (offshore companies, trusts, foundations, communities of heirs) or where the new EU rules leave room for doubt — we recommend consulting a lawyer specialising in Spanish anti-money-laundering law and, on tax questions, a tax adviser. Doxario is a deal management and compliance platform for estate agents in Spain, operated by Blue Pepper S.L.; we therefore have an economic interest in the solutions described in these FAQs. Doxario accepts no liability for decisions taken solely on the basis of these FAQs.
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