Anti-money-laundering duties for estate agents in Spain
Estate agencies across the whole of Spain are obliged subjects under Ley 10/2010, the anti-money-laundering law, with no regional exemption. You must appoint a representative before SEPBLAC, train staff, identify clients and beneficial owners, and keep records for ten years. What gets penalised is not having the system, whether or not any laundering occurred.
What you need in place
- A representative before SEPBLAC (Spain's anti-money-laundering supervisor), formally appointed
- A written, approved prevention manual
- A documented risk analysis
- Staff training, delivered and evidenced, on a recurring cycle
- Identification of clients, and of the beneficial owner where the buyer is a company
- Retention of documentation for ten years
The small-agency relief
Agencies with fewer than 10 employees and under 2 million euros of turnover are excused the documented risk analysis and the written manual. Those two things only: every other duty applies in full.
The two conditions are cumulative - you need both. A great many Costa del Sol agencies sit right on the line. Calculate rather than assume: taking the relief when it does not apply is exactly the kind of oversight that gets sanctioned.
Ten years of retention, and the tension with GDPR
The ten-year retention duty sits awkwardly against GDPR's push to keep less data. Your retention policy has to name the Ley 10/2010 basis explicitly, or it ends up contradicting itself.
What actually gets fined
What is penalised is not a particular laundering transaction but the failure of the duties themselves: not examining suspicious operations, identifying clients poorly, not keeping the documentation. These are infringements in their own right, which is why an agency that has never touched a suspicious deal can still be penalised for not having the system in place.
Check a licence number
Free, no sign-up, nothing stored. Try VUT/MA/102186.
Sources
- Ley 10/2010, de 28 de abril, on the prevention of money laundering
- Comisión de Prevención del Blanqueo - guidance for the property sector
- RD 304/2014, implementing regulation — the regulation implementing Ley 10/2010, consolidated text
Verified against the sources above on 2026-08-12. LicenceDesk is operational guidance, not legal advice.
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