The Compliance Gap in Spanish Real Estate

Where the gap is

Real estate sits under SEPBLAC supervision but most agencies still operate without a written AML manual, without a customer risk model and without an audit trail for the KYC files they hold.

What is coming

• More targeted supervisory action by SEPBLAC.
• The AMLA single rulebook raising the floor across the EU.
• Greater scrutiny of beneficial ownership in cash-heavy transactions.
• Higher expectations on document security and retention.

What good looks like

A documented risk-based approach, a KYC platform with audit logs, a defined retention schedule and clear escalation paths to the internal control body.