Spot what does not add up before it becomes a problem.
A successful sale is not just about moving quickly. It is also about knowing when to stop, verify and protect the client, the agency and the transaction itself.
- Pause
- Verify
- Document
- Escalate
- Communicate calmly
A warning sign alone does not prove fraud. It indicates that something needs to be clarified before accepting money, signing documents, listing a property or proceeding with the transaction.
Assess facts, not personal profiles
The review must be based on the transaction, the documentation, the source of funds, representation and the consistency of the information. Never use age, nationality, appearance, accent, gender, disability or any other personal characteristic as a substitute for a professional assessment.
Apply the same protocol
Use the approved process for identification, documentation and payments with every client. Consistency protects the team and reduces improvised decisions.
Look for consistency
Personal details, financial capacity, the purpose of the purchase, ownership and payment methods must form a clear and verifiable story.
Record specific facts
Note what was received, what did not match, what was asked, what the client answered and who approved the next step. Avoid personal opinions or labels.
Why this process matters in Spain
Those professionally engaged in agency, commission or intermediary activities in the purchase and sale of real estate are included among the obliged entities under Spanish anti-money laundering regulations. Identifying the client, the beneficial owner and the purpose of the relationship forms part of the due diligence measures. [1]
Use this traffic light before proceeding
The aim is not to judge the client. It is to determine whether you can proceed as normal, whether you need clarification, or whether you must stop an irreversible action and request an internal review.
The information is consistent
You can proceed by following the usual procedure.
- Identity and authority to act verified.
- The purpose of the transaction is clear.
- Documents are consistent with one another.
- Payments are traceable and the account has been confirmed.
There is something that still needs clarification
Pause the affected step and request additional information.
- Incomplete details or minor discrepancies.
- Unexplained involvement of a third party.
- Unusual urgency to reserve or transfer funds.
- A document that cannot yet be verified.
Do not take the next step
Preserve evidence and activate the internal procedure.
- Possible forgery or impersonation.
- Urgent change of bank account.
- Request to conceal the price or payments.
- Inability to identify the parties.
Warning signs and how to respond
Use these cards during client onboarding, qualification, reservation, negotiation, signing and payment follow-up.
Identity and authority to act
- The name, photograph, signature, telephone number or address does not match across the documents.
- The person avoids identifying themselves or only sends incomplete, low-quality screenshots.
- Someone acts on behalf of the buyer or seller but does not provide a verifiable power of attorney or authorisation.
- A company is involved, but it is unclear who represents it or who its beneficial owner is.
Verify identity in accordance with the internal procedure. When a company or representative is involved, verify their authority to act and beneficial ownership before proceeding.
How to say it: To protect all parties, we need to complete identity and authority-to-act verification before moving forward.
Purpose and source of funds
- The transaction does not align with the activity or financial means stated.
- The funds come from an unrelated person or company without a clear reason.
- Transfers from multiple accounts are proposed without explanation.
- There is a request to declare a different price, conceal a payment or split it to avoid checks.
Request a documented explanation of the purpose, the activity and the source of the funds. If the information remains inconsistent, refer the case to the internal compliance officer.
How to say it: We need to understand and document the source of the payment and who is involved in it. This is a standard transaction check.
Ownership, encumbrances and property status
- The seller does not match the registered owner.
- The land registry extract is outdated or shows mortgages, attachments, restrictions or other unexplained encumbrances.
- The floor area, use or description does not match between the Land Registry, Catastro, deed and physical reality.
- There are occupants, tenancies, works or extensions whose status is not documented.
Obtain up-to-date Land Registry information and compare the ownership, encumbrances, deed and cadastral data. Request a legal review where there is any relevant discrepancy. [3] [4]
How to say it: Before presenting the property as ready to sell, we need to confirm ownership and resolve these documentary discrepancies.
Price, reservation and payment methods
- There is pressure to pay before receiving written terms.
- A request is made to deposit money into a personal, unknown or different account from the one previously verified.
- The price is unusually high or low without a clear commercial justification.
- A request is made to return funds to an account other than the one from which they were received.
Use only contracts, receipts and accounts approved by the agency. Confirm in writing the purpose, amount, account holder and refund terms.
How to say it: We will not send payment instructions until the terms and destination account have been verified through our process.
Documents and signatures
- Dates, names, numbers or signatures do not match.
- There are missing pages, cropped areas or elements that appear to have been added.
- The document comes from an unrecognised domain or contact.
- There is insistence on using a modified version outside the approved system.
Request originals, verifiable copies or documents obtained through an independent source. Keep the version received and do not alter the original file.
How to say it: Information does not match between the versions. We need a verifiable copy before we can use the document.
Third parties, companies and powers of attorney
- One person responds for all parties and avoids direct contact with the client.
- The company structure is unnecessarily complex for the transaction described.
- The power of attorney provided does not clearly identify the property or the necessary powers.
- The payer, buyer and beneficial owner do not match, and there is no documented explanation.
Identify each participant, their role, their authority to represent, and the relationship between them. Request legal review when the authority or structure is unclear.
How to say it: We need to identify each person's role and confirm who can make decisions and sign in this transaction.
Impersonation and bank account changes
- A new IBAN arrives by email or messaging just before a transfer.
- The message demands urgency, confidentiality or that you do not consult anyone else.
- The sender's domain has one different letter or a new contact account is used.
- An unexpected invoice or instruction is attached with modified bank details.
Stop the payment. Confirm the change using a previously known number or channel, not using the details included in the suspicious message. Apply dual verification before authorising the transfer. [5]
How to say it: For security reasons, no account change is validated solely by email. We will confirm it through an independent channel.
Pressure, urgency and bypassing the process
- “It has to be signed today” without a verifiable reason.
- You are asked to avoid the lawyer, notary, bank or compliance officer.
- The client repeatedly refuses to provide basic information but insists on proceeding.
- You are asked not to issue a receipt, invoice, contract or record for part of the agreement.
Slow down, identify what is missing and explain the next step. Do not argue or accuse. When the client attempts to avoid essential checks, escalate the case.
How to say it: I understand that time is important, but we cannot skip this check. Once it has been resolved, we will continue.
An unusual transaction requires analysis, not an automatic conclusion
Regulations require transactions to be examined with particular attention when they are complex, unusual, lack an apparent economic purpose or show signs of simulation or fraud, and the result of the examination must be documented. [1] [2]
When something does not add up, use PAUSE
This method helps maintain a calm, professional and documented response, even when there is pressure to proceed.
Pause
Stop irreversible action: payment, signing, handover of keys, publication or sending sensitive data.
Clarify
Identify exactly which detail, document, person or instruction is inconsistent.
Use independent sources
Verify through the Land Registry, notary, bank, known channel, original document or official source.
Escalate the case
Notify the appropriate person: management, legal counsel, compliance or IT security.
Document
Record the facts, documents, responses, checks and the decision made.
How to request information without creating tension
Talk about the process and protecting the transaction. Avoid accusing, speculating or using language that could make the client feel singled out.
“This check applies to all our clients. We need verify identity and, where applicable, authority to represent before proceeding.”
Explain which document you need, how it will be used and what the next step is.
“We see that the payment will come from a different account. Could you explain the relationship and provide the relevant supporting documentation?”
Ask an open-ended question. Do not present a suspicion as a fact.
“For security reasons, any change of account requires confirmation through a previously verified channel before making the payment.”
Do not use the phone number or link included in the same message that communicates the change.
“There is a pending check. We will pause this step until it is resolved and let you know exactly what we need.”
Offer an action and a realistic timeframe. Do not promise approval before completing the review.
Decide who should review the case
Adapt this matrix to your agency's procedures manual. Not all issues are legal, nor do all discrepancies imply fraud.
| Level | Examples | Immediate action | Recommended person responsible |
|---|---|---|---|
| 🔵 Operational | Outstanding document, incomplete information or minor discrepancy that can be clarified. | Pause the affected step, request information and record the response. | Agent responsible or transaction coordinator. |
| 🟡 High | Unexplained third party, IBAN change, questionable power of attorney, inconsistent ownership or funds without clear justification. | Do not receive or send funds. Keep documents and request a review. | Management, legal counsel, compliance officer or IT security. |
| 🔴 Critical | Possible forgery, impersonation, deliberate concealment, fraud or indications related to money laundering. | Do not proceed with the affected transaction. Apply the internal protocol and preserve all evidence. | The AML/CFT officer and authorised management, with legal or technical support where appropriate. |
Do not disclose a review or report based on an indicator
When a transaction is being examined for a possible connection to money laundering or terrorist financing, do not inform the client that a report is being considered or has been submitted to Sepblac. Follow only the authorised internal procedure. [1]
What an agent should not do
Accuse the client of fraud or money laundering based solely on an impression.
Accept reservations or payments into a personal account or one not approved by the agency.
Confirm a change of bank details by replying to the same email that requests it.
Edit, overwrite or delete the original document that triggered the alert.
Promise a legal, tax, land registry or mortgage outcome beyond your competence.
Skip a check because the client appears trustworthy, is known to you or demands an urgent response.
Agent checklist
Tick each item only once it has been verified. This list does not replace your agency's internal procedure.
Common agent questions
Does a warning sign mean the client is committing a crime?
No. A warning sign indicates that there is an inconsistency or risk that must be analysed. You must not accuse anyone or draw conclusions without a proper review.
Can I continue showing properties while documentation is missing?
It depends on which document is missing and on your agency's procedure. agency. You must not proceed with actions that require identification, representation or approval that has not yet been completed.
What should I do when a client is upset by the checks?
Explain that these are standard checks applied to protect all parties. State what information is needed, why it is needed and what the next step will be.
Should I verify an IBAN even if the email appears genuine?
Yes, when it concerns a new account or a change in instructions. Confirm through a previously known channel and apply the agency's approved authorisation system.
Who decides whether a transaction is reported to Sepblac?
The internal prevention procedure must be followed and the case must be reported to the designated person in charge. The agent must not improvise, inform the client or make a report outside the authorised process.
Regulations and reference resources
- BOE — Law 10/2010 on the prevention of money laundering and terrorist financing
- Sepblac — Recommendations and risk indicators for obliged entities
- Spanish Registrars — Guidance on encumbrances and the safe purchase of residential property
- General Council of Notaries — Homes and real estate
- INCIBE — Verification of transfers, bank accounts and urgent requests