A check, recorded to the minute.
Every source accounted for.

Product concept — no live checks, accounts or reports yet.

FEHARA is being designed for Spanish sujetos obligados — notaries, real-estate agents, lawyers and gestorías. The planned workflow would record the legal basis, queried sources, their responses and any gaps in one case report.

OFAC EU UN OpenSanctions Interpol PEP no response 10:42:12 SEALED · SHA-256 · ANCHORED · LIVE SOURCES · SEALED · SHA-256 · ANCHORED · LIVE SOURCES ·

Built for sujetos obligados

Spanish Law 10/2010 obliges these professionals to identify their clients, screen them against sanctions and PEP lists, and be able to show they did. FEHARA starts with the four roles that do it every week.

Notaries

Property and company deeds. Identify the parties and beneficial owners, screen them, keep the record ready for inspection.

Realtors

Sales and high-value rentals. A check on the counterparty of a real deal — tied to the operation, never to curiosity.

Lawyers

Transactions, company formation, trusts. Due diligence handed over as a sealed file, not a screenshot.

Gestorías

Company registrations and tax services. Beneficial-owner checks on legal persons, repeated with every new mandate.

Next, by demand:
Accountants & auditors Property administrators Insurance brokers Car & luxury dealers Crypto-asset providers Currency exchange

One record should show the whole check

A useful compliance record makes its scope and limits easy to see. This is the format FEHARA is being designed around.

Check record · proposed structureDesign concept · not a live report
01

Basis & operation

Why the check is being conducted, and which operation it relates to.

02

Sources consulted

Which sources were in scope, with official authorities distinguished from aggregators.

03

Coverage & gaps

What responded, what did not, and whether any information was cached or unavailable.

04

Time & context

When each response was received, with enough context to understand the record later.

These are product design requirements. FEHARA does not yet run checks or issue records.

Proposed check workflow

This sequence is a design concept. It is not a live service.

  1. 01
    The checker is verifiedEvery checker first proves sujeto obligado status: notary number, realtor licence, company NIF. There are no anonymous accounts.checker.verified10:42:01
  2. 02
    The right to check is computedRules per jurisdiction decide whether this role may run this check on this basis. A realtor may check a deal counterparty — not a neighbour.mandate.allowed10:42:02
  3. 03
    The subject is notifiedThe person being checked receives an alert and confirms it. Secret checks of strangers are impossible by design.subject.confirmed10:42:05
  4. 04
    Sources are queried liveAuthorised first-party sources are asked in parallel at that moment. A cached source is labelled with its age.sources.answered5/6 · 10:42:12
  5. 05
    The result is sealedChecker, basis, notification, every source response and every failure are hashed and anchored outside FEHARA.attestation.sealed10:42:12
  6. 06
    The report is issuedA PDF the professional files as evidence of compliance.report.issued10:42:13
Illustrative example · fictional record
FEHARAPRV-0417-ES · 13.09.2026 · 10:42

The report says

✓
No match found in the sources checked on 13 Sep 2026 at 10:42.
✓
UN sanctions did not respond at check time.
✓
PEP lists: cached copy, current as of 07:40.
✕

It never says

“Clean.”
“This person is innocent.”
“All sources checked” — while one was down.

On what basis. The check rests on the professional's own obligation under Ley 10/2010. The subject's confirmation is a safety and transparency channel, not the legal basis for processing. Legal texts are under review by Spanish data-protection and AML lawyers.

Sources — and the line FEHARA does not cross

FEHARA is designed to distinguish official first-party authorities from aggregators. Aggregated data is not an authority on its own; a report should identify which source supplied each fact.

Included

Basic layer — instant

Query a first-party source at check time where available. Label any permitted cached result with its age.

  • OFAC — US Treasury sanctions
  • EU consolidated sanctions list
  • UN Security Council sanctions
  • OpenSanctions — aggregator, not an authority
  • Interpol public notices
  • Politically exposed persons
On request

Extended layer — per case

Contracted sources, billed per request or by package. Never a free ‘check anyone’ surface.

  • Licensed commercial data sources
  • Company and business registries
  • Identity document authenticity
  • Email, phone or username lookups — only tied to a specific case and basis
Never

The red line

Not accessed under any circumstances — not with consent, not on request, not for any price.

  • Internal police databases
  • Non-public Interpol data
  • Leaked or stolen databases
  • Schengen Information System (SIS)

Principles for the planned record

These are requirements for a future service, not guarantees of a system that is already operating.

Freshness to the minuteA live answer from the source at check time, not a copy from yesterday. Where a live query is impossible, the cache age is printed — and past its allowed window the report demands a live recheck.
Honest completenessEvery report states how many authorised sources answered and names the ones that did not. A missing source is never dropped silently.
Cannot be backdatedThe attestation is hashed and anchored outside the platform. Not even the operator can rewrite or backdate a record after the fact.
Both sides verifiedThe checker is a KYC subject too. Nobody can pose as a realtor to look someone up, because a fake realtor does not pass verification.
The right to check is computedRules combine role, jurisdiction, basis and check type, written together with a local lawyer. Without a valid rule, the check does not start.
The operation, not only the personChecks are attached to the operation they serve — the deal, the deed, the case — because that is the unit AML compliance is judged on.

Beyond the single check

The same sealed records serve two more needs of a sujeto obligado.

Annual external reviewSujetos obligados must have their internal controls reviewed by an external expert every year. An export of a period's sealed checks turns a week of sampling into an hour.
EU Digital Identity WalletSpain's wallet is due for citizens from November 2026. FEHARA plans to register as a relying party when the national register opens — for identity attested by the state instead of scanned documents.

Build status

FEHARA is in its specification and validation phase and is not accepting clients. This list shows what exists, not what is promised.

1
SpecificationTarget market, source layers, rules engine, freshness policy, attestation model, report format.
done
2
Legal reviewLegal basis, Article 10 GDPR scope, liability wording — with Spanish data-protection and AML lawyers.
in progress
3
Validation interviewsConversations with notaries and realtors in Guardamar and Torrevieja before the build.
next
4
Core engineSource adapters, rules engine, notification channel, attestation sealing.
planned
5
Reports & client consoleSealed PDF reports, operation files, period export for external reviewers.
planned
6
EUDI relying partyRegistration when the Spanish register of relying parties opens, from 24 December 2026.
planned
Not a service yet. There is no sign-up, no trial and no public API. FEHARA does not replace legal counsel: every text a regulator will read is reviewed by a Spanish lawyer before launch.