Spain’s estate agents reported 17 suspicious transactions in 2025. On 28 October, a rule changes for the small ones.

Picture this: a foreign buyer wants to close on a villa in Marbella before the end of the month. They are buying through a company nobody at the agency has heard of, and the money will come from a third country. In the office, someone remarks that something does not quite add up. There is a short discussion, a couple of documents are requested and the sale goes ahead. It may all have been perfectly legitimate. But nothing from that conversation is written down.

I start there because the figure in this note invites a different debate, about whether agencies report too little. I think that debate leads nowhere. The useful question is another one: if someone asked your agency tomorrow to explain that transaction, what could it show?

The figure.

Sepblac, Spain’s financial intelligence unit, publishes every year where the suspicious transaction reports it analyses come from. In 2025, real estate intermediaries across the whole country filed 17, against 63 in 2024 and 24 in 2023. That is 73% fewer than the year before, and they came from just 9 obliged entities. It is 0.6% of the 2,881 reports from non-financial entities, which are themselves a part of the 21,667 in total.

Next to them, in the same table, property developers filed 94, up 54%, from 40 obliged entities. Notaries filed 573 and land registrars 747, in both cases through their central body. Dealers in jewellery and precious metals, 56. Casinos, 17: the same as every estate agency in the country.

What the figure does not say.

It needs careful reading. These are reports Sepblac analysed, not exactly the ones it received. Figures for earlier years have been revised. And with numbers this small, any percentage swings a lot. Besides, a sale does not pass through the agency alone. It passes through the bank, the notary and the land registry, and all of them are obliged entities. The agency may see little of the money, and the report may come from elsewhere.

So I do not know whether 17 means agencies see little or report little. Nobody can tell from the table. What I do know is that whoever reads it from a supervisor’s desk asks exactly that question. And the answer is not in the table. It is in each agency’s files.

What changes on 28 October.

On 8 October 2026, Spain’s Official Gazette published Royal Decree 813/2026, which amends the regulation implementing the anti-money laundering act and comes into force on 28 October. Until now, small obliged entities, including agencies with fewer than ten people, counting their agents, and no more than €2 million in turnover or balance sheet, were exempt from appointing a representative to Sepblac. That exemption is gone. They have nine months from entry into force to notify the appointment, which by my calculation means the end of July 2027.

The same decree adds another nuance. When an agency has not been able to complete customer due diligence at the start of a relationship, it will have to analyse, after a special examination, whether to report that to Sepblac. Small agencies remain exempt from other internal control duties, such as the manual, the written risk analysis, the external review and training. That exemption never covered identifying the client and whoever stands behind them, the special examination or reporting. I am not a lawyer, and which duties apply to your agency is for a specialist to confirm.

The blind spot: the examination that ends without a report.

Spain’s anti-money laundering act lists among obliged entities those who professionally act as intermediaries in the sale of real estate. Its Article 17 requires them to examine with special attention any transaction that is complex, unusual or without an apparent economic or lawful purpose, recording the results of the examination in writing. It does not say only when the result is suspicious. It says the results.

The regulation spells it out. The special examination is carried out in a structured way, documenting the stages of analysis, the steps taken and the sources consulted. A chronological register records, for each file, the opening and closing dates, the reason, the conclusion and the decision whether to report, and it is kept for ten years. The Marbella sale may have been flawless. What was missing was not a report. It was the file explaining why none was needed.

Seventeen reports do not tell you whether an agency is careful. The files on the transactions that were not reported do.

Where I stand.

A luxury agency does not protect itself by reporting more just in case. It protects itself by being able to explain every decision, with a date and a name. And that is where my work comes in: a buyer’s information arrives first through the website, a form, a chat or an email, and it ends up in a CRM. If that system records who is buying, who is paying, from where and what was checked, the file gets written while the work is being done. If it does not, it depends on someone’s memory. Diligence that is not written down is very hard to prove.

What I would check.

• Who represents the agency. Who will be the person appointed to Sepblac, and whether the team knows whom to alert when something does not add up.
• Who pays. That the system distinguishes between who signs, who pays and who the beneficial owner is, especially when a company is buying.
• The register of examinations. Opening and closing date, reason, conclusion and decision, including when the decision is not to report.
• What conversations say. That a remark like “this doesn’t add up” has a place to be recorded instead of getting lost in a corridor.
• Ten years. Where all of this is stored and whether it can still be found in 2036.

Where to start.

1. This week

   Look back

   Pick five 2026 sales with a foreign buyer or a company and check whether there is a written trace of what was reviewed.

2. Before the end of the year

   Confirm the scope

   With your lawyer or AML specialist: which duties apply to you and who will be your representative to Sepblac.

3. This quarter

   Build it into the system

   So each buyer record captures who pays, the beneficial owner and the register of examinations, with no extra steps for the team.

4. Before July 2027

   Notify the appointment

   If your agency was exempt, within the nine-month period set by the Royal Decree.

Seventeen reports in a year, for a whole sector. You can read it as proof that almost nothing happens, or as proof that almost nobody looks. The figure does not decide which reading is right. Your files do.

Find the last transaction where something made you hesitate: a payment from a third country, a buyer in too much of a hurry, a company set up last month. Could you find today, in writing, why you went ahead? And could someone else in your agency find it if you were not there?

If you would like me to review how a buyer’s information enters your website and your CRM today, and whether it leaves the trail your agency needs, start with the Strategic Diagnostic. What obligations your agency has and how to meet them is for your lawyer or your compliance adviser to decide, not a designer.