AML compliance program for a real estate development group

The Challenge

A real estate development group with annual transaction volumes exceeding 200 million euros received an inspection notice from SEPBLAC (Spain’s Executive Service for the Prevention of Money Laundering and Monetary Offences). The initial assessment was alarming: the company lacked an up-to-date internal prevention manual, had no risk-based customer evaluation system, and its due diligence procedures (KYC/KYB) were entirely formal with no substantive controls.

Given that the real estate sector is classified as high-risk under FATF standards and Spanish law (Law 10/2010), the exposure to sanctions was substantial. The law provides for fines of up to 5% of annual turnover for serious breaches — a potential liability exceeding 10 million euros for this group. Beyond the financial risk, a formal sanction from SEPBLAC would have damaged the company’s standing with its international financing partners at a critical moment of portfolio expansion.

Our Approach

BMC began with a comprehensive gap analysis mapping all requirements under Law 10/2010 against existing controls. From that diagnostic, we structured the implementation in three parallel workstreams over a 90-day horizon.

The first workstream involved drafting an Internal Prevention Manual tailored to the group’s specific client typology and transaction profile, including risk classification by customer profile, jurisdiction of fund origin, and transaction complexity. Simultaneously, we designed simplified and enhanced due diligence templates (KYC/KYB) and integrated them into the commercial pre-sale process.

The second workstream established the internal control mechanisms: a suspicious transaction reporting system, sector-specific early-warning indicators (fragmented cash payments, opaque financing structures, sudden ownership changes), and a formal reporting channel to SEPBLAC. We appointed the SEPBLAC Representative and constituted the AML Compliance Committee with defined responsibilities and escalation procedures.

The third workstream focused on training and culture: we delivered a structured training program to all 120 group employees, differentiated by risk exposure level, with individual documentary certification for each participant. The complete implementation dossier was prepared and organized for the inspection.

Results

The SEPBLAC inspection proceeded as scheduled. Inspectors identified only minor observations on procedural documentation aspects, which were addressed during the inspection itself. No sanction was imposed and no urgent remediation requirement was issued.

The group now operates a fully functional AML program, externally audited and formally recognized by SEPBLAC as adequate. The implementation has reinforced confidence among the group’s international financing partners, several of whom had conditioned new credit facilities on the existence of robust AML controls — those conditions have since been lifted.