Documentation and audit trail
No. Software can structure capture, timestamping and traceability — the substantive risk assessment and the decision in the individual case remain the agent's task as a sujeto obligado.
Confusing the tool with the check is one of the recurring documentation patterns: structured documentation records that an assessment took place and how. It does not replace it.
What software can do:
What it cannot do: replace the substantive risk assessment, the agent's professional judgment, or legal advice in the individual case.
Legal basis: Ley 10/2010, Art. 25; Art. 2.1(l)
Practical tip: A flawlessly kept file with a poorly reasoned risk classification is no better placed at inspection than a bad file — it just documents the thin assessment more tidily. The tool improves traceability, not judgment.
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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