What happens if I fail to identify the UBO correctly?

It can constitute a "serious" (grave) infringement under Art. 52.1.b) Ley 10/2010, sanctionable under Art. 57. The law grades infringements in three tiers — leve (minor), grave (serious) and muy grave (very serious) — and the assessment in the individual case follows Art. 59. Alongside the fine against the agency stands the personal liability of directors and senior management (Arts. 54 and 57.2.a). There is no single figure that can be cited generally.

Art. 52.1.b) classifies a breach of the Art. 4 obligations as serious — that is, precisely the obligations to identify the beneficial owner and verify their identity. That covers not only an incorrect declaration but also an omitted or inadequate check.

In practice this means the file must show what you checked and what your attribution rests on. In a structure where nobody exceeds 25%, establishing that very fact belongs in the documentation — otherwise there is no way to tell from outside whether you looked and found nothing, or never looked at all.

Legal basis: Ley 10/2010, Art. 52.1.b), Art. 57; Art. 4

Practical tip: Requesting the documentation too late is the mistake that most readily leads here. Querying beneficial ownership only after the reservation is signed turns due diligence into a race against the transaction timetable as well — and time pressure is the reason chains are left incomplete.