Source of funds
In a low-risk case it can suffice as a starting point — but the explanation itself, the assessment of its plausibility, and the reasoning behind the risk classification must all be documented. Whether it suffices on its substance depends on the risk and plausibility of the case; where risk is elevated, additional documentation may be required. SEPBLAC (Servicio Ejecutivo de la Comisión de Prevención del Blanqueo de Capitales, Spain's financial intelligence unit) does not prescribe a fixed document catalogue.
What matters is that these three points are in writing, not that the buyer's statement is:
Without those records, a verbal statement is not evidence after the fact, it is an assertion. If it comes to it, the agent must be able to show what the assessment rested on.
Legal basis: Ley 10/2010, Art. 6
Practical tip: Many buyers are reluctant, for private reasons, to disclose where their money came from — understandable, but it changes nothing about the legal position. An agent who documents too little out of misplaced deference ends up carrying the risk personally, not the buyer.
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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