The more senior the position, the greater the potential economic, reputational and legal damage caused by a poor hiring decision. For C-Level positions, board roles and profiles with significant financial responsibility, a standard background check is rarely sufficient.

What Enhanced Due Diligence adds

In addition to the usual modules (identity, education, employment history), Enhanced Due Diligence for a senior role in Spain includes:

Permit verification: particularly relevant for executives recruited internationally, where checking work and residence authorisation is essential to avoid legal risks in the hiring process.

Conflicts of interest: shareholdings in competing companies, undisclosed mandates on other boards, or parallel activities that could interfere with the new role.

Screening against international sanctions lists: those of the European Union and the United Nations, with particular attention to result quality and manual verification of name matches (false positives).

Reputational analysis and “Leak Papers”: reviewing global media coverage of the individual and searching for their presence in leaks such as the Panama Papers or Paradise Papers in order to identify undisclosed offshore activities.

International criminal records: where the individual has worked abroad during the previous 5 to 10 years, using European mechanisms such as ECRIS or ECRIS-TCN.

What is a Politically Exposed Person (PEP)?

Article 14 of Law 10/2010 on the prevention of money laundering and terrorist financing defines PEPs as persons who hold or have held prominent public functions (heads of state or government, ministers, parliamentarians, senior judicial officials, central-bank officials, senior military officers, directors of state-owned enterprises or executives of international organisations), as well as their close family members and close associates. By definition, a PEP presents a higher risk of bribery, corruption and money laundering, which justifies a higher level of diligence.

Who monitors sanctions lists in Spain?

The Executive Service of the Commission for the Prevention of Money Laundering (SEPBLAC), Spain’s financial intelligence unit, does not maintain its own sanctions list: companies and obliged entities must consult the official lists of the European Union and the UN Security Council, supplemented where appropriate by lists such as OFAC in cases involving exposure to US-dollar transactions.

Why this is also about financial integrity

A C-Level screening must examine the candidate’s financial integrity, particularly for roles with budget responsibility such as CFO. The lawful tool in Spain, as explained in the article on ASNEF and the Public Insolvency Register, is the latter public register, not private creditworthiness databases.

See also: Human Risk and Background Checks in Spain: The 2026 Reference Guide, Human Risk in Spain: What It Is and How Companies Manage It with Background Checks and ASNEF, RAI and the Public Insolvency Register: What an Employer in Spain May (and May Not) Check