Do staff at an estate agency have to be trained?

Yes. Under Spanish law, everyone at an estate agency who deals with clients or works on transactions must receive regular anti-money-laundering training. It is an obligation, not a voluntary measure.

Art. 29 Ley 10/2010 requires obliged entities to train their staff periodically in anti-money-laundering matters. This covers not only the agents themselves but everyone who:

• opens or works on client files
• deals with clients directly
• administers documentation
• supports compliance processes

On content, the training must cover at least:

• the legal basis (Ley 10/2010, Real Decreto 304/2014, the forthcoming AMLR)
• recognising red flags and indicators of suspicion
• handling PEPs and sanctions lists
• documentation and retention duties
• reporting routes, internally and to SEPBLAC
• the penalties that follow from non-compliance

Every training session must be documented — attendance list, content, date. In a SEPBLAC inspection those records can be called for.

On the state of the law: Real Decreto 813/2026, de 7 de octubre (BOE-A-2026-20915) amended the exception catalogue in Art. 31.1 RD 304/2014 and removed Art. 35 — the dedicated internal control body — from it with effect from 28.10.2026. For small offices the outcome is unchanged, because Art. 35.2 itself governs when such a body is not required; the chain of norms, however, is now a different one.

Legal basis: Ley 10/2010, Art. 29; Real Decreto 304/2014, Art. 39 (as amended by Real Decreto 813/2026)

Practical tip: Offices with temporary staff (interns, casual help) must give those people a short briefing too, before they handle any client data. An internal training handbook in the office's working languages is worth having.