Documentation and audit trail
The statute does not prescribe a general four-eyes requirement. It is an organisational measure that strengthens the traceability of a decision — particularly useful where a risk assessment is not clear-cut.
The distinction matters because it governs how you handle it: as a legal duty, four-eyes review would have to be applied uniformly everywhere. As an organisational measure, it is deployed where it adds something — on ambiguous classifications, complex structures, unusual payment routes.
It therefore sits in the same group as the other practices that strengthen traceability without being legally required: recording the decision rather than just the outcome, anchoring the timing, keeping versions instead of overwriting, one file per matter instead of scattered channels.
Legal basis: Ley 10/2010, Art. 25 (documentation); no four-eyes requirement is laid down by law
Practical tip: In a small office the second pair of eyes often doesn't exist. Written reasoning then takes its place: whoever decides alone should record all the more precisely which factors were assessed and how they were weighed.
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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