Source of funds
If doubts persist, an internal review of the suspicious circumstances and, where applicable, a report to SEPBLAC may become necessary.
That decision rests with the obliged entity — it cannot be sidestepped out of deference to the buyer. Two steps come first: asking, and recording your own assessment together with what it rests on. Only where doubts persist despite all the questions does the question of an enhanced review arise.
The case where no report is ultimately filed needs recording too: the deliberation itself, its basis, and the outcome belong in the file. Otherwise there is no way to show later that anything was examined at all.
Legal basis: Ley 10/2010, Art. 17 (examen especial), Art. 18 (reporting)
Practical tip: The uncomfortable moment is not the report, it is the conversation before it. An agent who raises source of funds early and as routine does not have to frame it later as suspicion — and keeps the route to a factual clarification open instead of blocking it with an accusation.
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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