Risk assessment

What is the difference between CDD and EDD?

CDD (customer due diligence) is the standard obligation that applies to every client. EDD (enhanced due diligence) is the reinforced review where risk is elevated — with PEPs, offshore structures or unusual transactions, for instance. EDD means more documents, deeper checking and, where warranted, a report.

CDD (diligencia debida ordinaria) comprises, under Art. 4 Ley 10/2010 and Arts. 3–5 Real Decreto 304/2014:

  • identifying the client and verifying that identity
  • establishing the ultimate beneficial owner
  • understanding the purpose of the business and the transaction structure
  • risk classification
  • ongoing monitoring

EDD (diligencia debida reforzada) is mandatory under Arts. 11–16 Ley 10/2010 for:

  • PEPs (politically exposed persons)
  • high-risk third countries (the so-called blacklist)
  • complex corporate structures with no discernible economic purpose
  • transactions with an unusually high cash component
  • clients from countries with strategic deficiencies (FATF grey or black list)

Anyone applying EDD must in addition:

  • obtain further independent documents (tax certificates or bank references, for example)
  • verify the business actually carried on
  • examine the origin of the wealth in more depth (origen del patrimonio)
  • monitor and document the transaction more intensively
  • where appropriate, carry out an examen especial and inform SEPBLAC

Legal basis: Ley 10/2010, Arts. 3–8 (CDD), Arts. 11–16 (EDD); Real Decreto 304/2014, Arts. 3–5, 11

Practical tip: For Swiss or UK buyers (post-Brexit), CDD applies as a rule. Purchases through offshore structures (BVI, Cayman) or funded from crypto assets, by contrast, will generally establish a high risk and therefore EDD — though the actual classification remains a case-by-case risk assessment, not an automatic consequence.

Related questions

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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