Spain’s Real Estate Market: A High-Risk Sector for Money Laundering in 2024
- Andreas Hobbelin
- Mar 9
- 2 min read
The 2024 National Risk Assessment Addendum has reconfirmed that the real estate sector in Spain remains a prime target for money laundering (ML). Organized crime groups continue to exploit the sector's vulnerabilities to clean illicit funds, leveraging high-value property transactions, offshore structures, and Golden Visa schemes.
Key ML Risks in Spanish Real Estate
Golden Visas and Real Estate Investments
96% of Golden Visas granted between 2017-2022 were linked to real estate purchases.
These programs pose significant ML risks, particularly for high-risk individuals seeking EU residency through large property transactions.
Luxury Real Estate & High-Value Transactions
Criminal networks use luxury properties to store and move illicit funds.
Frequent resales, overvaluation, and layering through shell companies create opaque ownership structures that make it difficult to track the real source of funds.
Corruption & Real Estate Professionals
Notaries, registrars, and real estate agents play a crucial role in ensuring compliance.
However, the sector remains highly vulnerable due to subjective property valuation, under-the-radar cash payments, and weak beneficial ownership transparency.
Money Laundering through Property Flipping
Properties are bought and sold multiple times among related parties or shell companies to create layers of transactions that obscure the original illicit source of funds.
Why This Matters for the Real Estate Sector in Costa del Sol
Spain's attractiveness for foreign investors, especially in Costa del Sol, makes it a hotspot for ML risks. Real estate professionals, law firms, and financial institutions must apply enhanced due diligence (EDD) to detect and prevent suspicious transactions.
How CostaAML is Taking Action
At CostaAML, we provide:
✔️ AML Risk Assessments tailored for real estate professionals.
✔️ Enhanced Due Diligence (EDD) on foreign buyers and investors.
✔️ AML Compliance Training for real estate agents, notaries, and legal professionals.
✔️ AML Officer & External Expert Reviews to meet EUAMLD & Ley 10/2010 compliance requirements.