AssessmentPhase 1
Who is blocking and why
We determine whether the block is at the buyer’s bank, at the seller’s bank or in a transfer from abroad, and what information is missing.
The starting point.
Bank block on a property purchase in Spain
Days before signing, the bank won’t issue the check, holds the transfer of the price or blocks the money you have just received from the sale. It is almost always the same issue: the bank needs to know the source of the funds and, if it cannot verify it, Law 10/2010 prevents it from executing the transaction (Art. 7(3)). We prepare the justification so the purchase doesn’t fall through.
Has the bank blocked your property purchase? We’ll tell you what to do
Tell us whether you are buying or selling, the signing date and what the bank has told you, and we will guide you.
- Reply within 24 h
- No commitment
- Confidential
- Means of payment in the deed
- Notarial Law, Art. 24
- Cash with businesses
- Under €1,000
- Payments not identified
- No registration
- Spanish law
- Law 10/2010, Art. 7(3)
How we help
Getting the signing over the line
In a property purchase, a block has a deadline: the signing date. That is why we work in parallel with the bank and the notary’s office.
SourcePhase 2
Where the money comes from
We gather proof of the source of funds: savings, the sale of another property, an inheritance, a loan or money from abroad.
Dated and signed documents.
Money trailPhase 3
How it reaches the notary
We document the path of the money up to the check or transfer that will be handed over at signing.
No gaps in the chain.
DossierPhase 4
A file for the bank
We organize the documents with a clear explanation of the purchase, written for the bank’s AML department.
Ready to send.
NotaryPhase 5
Coordination with the notary
We prepare what the notary will ask for: identification of the means of payment and, if cash was brought from abroad, its declaration.
Before signing.
Follow-upPhase 6
Until the money is released
If the bank asks for more information or does not respond, we prepare the reply and, if needed, the complaint.
Until the case is closed.
Scenarios
Where a property purchase gets blocked
The block can occur before, during or after signing.
Buyer
Your bank won’t issue the check or make the transfer
Before paying out an amount like this, the bank wants to know where the funds in your account come from.
From abroad
Money from abroad doesn’t arrive in time
An international transfer for the purchase can get stuck at a bank until its source is justified.
Seller
The bank holds the price you have received
If the payment does not fit your profile, the bank may ask you for the deed and an explanation of the transaction.
Notary
The notary asks for more information
The notary is an obliged entity under Law 10/2010 and may request any information they need before authorizing the deed.
What the law says
Property purchases and money laundering, by the numbers
Figures from Law 10/2010, the Notarial Law, the Mortgage Law and Law 7/2012.
Law 10/2010, Art. 7(3)
No transaction
If it cannot apply due diligence, the bank does not execute the transaction, and it bears no liability for this unless there is unjust enrichment.
Notarial Law, Art. 24
Means of payment
The deed of sale states how much was paid, when and how: bank transfer, check or cash.
Mortgage Law, Art. 254(3)
No registration
If the parties refuse to identify the means of payment, the deed is not entered in the Registry.
Law 10/2010, Art. 19(2)
Notary
The notary may refuse to authorize the deed for just cause and obtains from the client the information they need.
Law 7/2012, Art. 7
€1,000
Cash payment limit when one of the parties is a business or professional; €10,000 for individuals without tax residence in Spain.
Law 10/2010, Art. 24
Confidentiality
The bank cannot tell you whether it has reported your transaction to SEPBLAC or whether it is examining it.
Do you have a signing date and the bank won’t release the money?
We review your case and tell you which documents are missing and how to submit them in time.
Frequently asked questions
Bank block on a property purchase: common questions
Why is the bank blocking the money for my property purchase?
Because Law 10/2010 requires it to know the source of its customers’ funds and to review transactions that do not fit what it knows about them (Art. 6). A property purchase is often the largest amount of money a person ever moves, and that triggers the review. If the bank cannot complete due diligence, it does not execute the transaction (Art. 7(3)).
What documents will I be asked for?
Those that prove where the money comes from: bank statements for the last few months, pay stubs or income tax returns, the deed of sale of another property, the inheritance documents, the loan agreement or the receipts for the transfer from abroad. And, always, the deposit contract (contrato de arras) or the draft deed for the purchase.
Can the purchase fall through because of the block?
It can be delayed, and if the money is not there in time, it can cause problems under the terms agreed in the deposit contract. That is why it is best to prepare the justification before moving the money and to give the bank notice well in advance. If you already have a signing date, we work in parallel with the bank and the notary’s office.
What does the notary ask about the payment?
The deed of sale must identify the means of payment: how much was paid, when and how (bank transfer, a bank check or other check, payable to a named person or to bearer, or cash) under Article 24 of the Notarial Law. If you pay with cash brought from abroad, the notary attaches the prior declaration of movement of means of payment.
What happens if the means of payment are not identified?
The notary records this in the deed, and the deed cannot be registered in the Property Registry (Article 254(3) of the Mortgage Law). It is a curable defect: it is corrected with a new deed that identifies all the means of payment (Art. 254(4)).
Can you pay for a home in cash?
If one of the parties is a business or professional (for example, a developer), you cannot pay €1,000 or more in cash; the limit rises to €10,000 if you pay as an individual without tax residence in Spain (Article 7 of Law 7/2012). And even if the payment is between private individuals, the deed will record how it was paid.
Will the bank tell me why it has blocked the money?
Not always. Article 24 of Law 10/2010 prohibits it from disclosing that it has reported information to SEPBLAC or that it is examining the transaction. What you can do is ask it to specify which documents it needs.
Can I file a complaint if the bank does not respond?
Yes. First with the bank’s customer service department, which has 15 business days to respond on payment services (Article 69 of Royal Decree-law 19/2018) and one month on all other matters. If it does not respond or you disagree with its answer, you can then go to the complaints service of the Bank of Spain.
Practical guide
How to avoid a bank block before signing
Most blocks can be avoided if the bank has the documents before the money arrives.
Prepare the justification
Gather proof of the source of funds as soon as you sign the deposit contract.
Notify the bank
Explain the transaction and hand over the documents before you request the check or the transfer.
Identify the payments
The deed will record how the price was paid: bring the receipts for each payment.
Your property purchase in 10 steps
- Keep the deposit contract and the receipt for the deposit you paid.
- Make a list of all the accounts the purchase money will come from.
- Gather proof of the source: pay stubs, the sale of another property, an inheritance, a loan or money from abroad.
- If the money is coming from abroad, prepare the justification before sending it.
- Give the documents to your bank before you request the check or the transfer.
- Ask the bank to confirm in writing whether it needs anything else.
- If your bank or the seller’s bank holds the money, ask in writing what is missing.
- Bring the receipts for all payments, including the deposit, to the notary’s office.
- If cash was brought from abroad, provide its prior declaration.
- If the bank does not respond in time, file a complaint with its customer service department and then with the Bank of Spain.
Source: Law 10/2010 (Arts. 6, 7, 19 and 24), Notarial Law (Art. 24), Mortgage Law (Art. 254), Law 7/2012 (Art. 7) and Royal Decree-law 19/2018 (Art. 69).
Working glossary
Key terms in a bank block on a property purchase
These terms come up in the bank’s requests, at the notary’s office and in Law 10/2010.
SourceProof
Source of funds
Where the money used to pay for the home comes from.
Law 10/2010, Art. 6.
CDDObligation
Due diligence
Measures the bank uses to identify the customer and check their transactions.
Law 10/2010, Arts. 3–7.
Means of paymentDeed
Identification of the means of payment
A statement in the deed of how much was paid, when and how.
Notarial Law, Art. 24.
RegistrationRegistry
Registry bar (cierre registral)
The deed is not registered if the parties refused to identify the means of payment.
Mortgage Law, Art. 254(3).
NotaryObliged entity
Notary
Applies Law 10/2010 and may refuse to authorize a deed for just cause.
Law 10/2010, Art. 19(2).
ArrasContract
Deposit contract (contrato de arras)
A contract signed before the deed, with a deposit and a signing date.
It sets the timeline.
RefrainingBlock
Duty to refrain from executing transactions
The bank does not execute a suspicious transaction while it reports it to SEPBLAC.
Law 10/2010, Art. 19(1).
CashLimit
Cash payment limit
Under €1,000 if one party is a business or professional; €10,000 for non-resident individuals.
Law 7/2012, Art. 7.
Customer serviceComplaint
Customer service department
The bank department where you file your first complaint.
15 business days for payment services.
Playbook
Where the block is and what to do
Buyer’s bank
What usually happens: it does not issue the check or make the transfer until it knows the source.
What you do: hand over the source-of-funds dossier.
Transfer from abroad
What usually happens: a bank holds it before it reaches your account.
What you do: find out where it is and justify its source.
Seller’s bank
What usually happens: it holds the sale price received until it understands the transaction.
What you do: provide the deed and an explanation of the sale.
Notary’s office
What usually happens: it asks for more information about the payments or the parties.
What you do: provide the receipts for all payments.
Property Registry
What usually happens: it refuses registration because the payments were not identified.
What you do: execute a new deed that identifies them.
Mistakes that block a property purchase
These are the errors that most often delay the signing.
- Moving the money at the last minute without having notified the bank.
- Paying the deposit in cash or from third-party accounts without documenting it.
- Bringing money from abroad without having the justification ready.
- Being unable to explain at the notary’s office how the deposit was paid.
- Splitting payments so they look smaller.
Contact
Book a call
Tell us whether you are buying or selling, the signing date, where the money comes from and what the bank has told you, and we will tell you what to do.
Property purchases under Law 10/2010 and at the notary’s office
Updated October 16, 2026
Several obliged entities under Law 10/2010 are involved in a property purchase: the banks of both parties, the notary, the land registrar and, if there is one, the real estate agency. Each of them has to know the source of the funds, and any of them can halt the transaction if it cannot verify it.
The bank
Article 6 of Law 10/2010 requires the bank to review transactions, “including the source of funds”. If it cannot apply due diligence, it does not execute the transaction (Art. 7(3)), and where there are signs of money laundering it refrains from executing it and reports it to SEPBLAC (Art. 19(1)). We explain this in duty to refrain from executing transactions.
The notary
Article 24 of the Notarial Law requires the means of payment to be identified in the deed. The notary may refuse to authorize the deed for just cause (several risk indicators, or a clear sign of a sham transaction or of circumvention of the law) and obtains the necessary information from the client (Article 19(2) of Law 10/2010).
The Registry
If the parties refuse to identify the means of payment, the deed is not registered (Article 254(3) of the Mortgage Law). The defect can be cured with a new deed (Art. 254(4)).
Cash
If one of the parties is a business or professional, you cannot pay €1,000 or more in cash, or €10,000 or more if you pay as an individual without tax residence in Spain (Article 7 of Law 7/2012). Real estate agencies and developers are also obliged entities: we cover this in anti-money laundering for real estate businesses.
Where it fits
To avoid a block, prepare your source of funds for buying a home in advance. If you need a formal document, we prepare a source of funds certificate, and if the problem is a transfer, see what to do about a transfer blocked by the bank.