KYC & AML Compliance
Source of Funds and Source of Wealth: what is the difference?
SU Legal Consultancy ·
Source of Funds and Source of Wealth are two of the most frequent requests in a due diligence file. They sound similar, but they answer different questions — and providing the wrong one is a common reason a file goes back and forth.
Source of Funds: this money
Where the money for a specific transaction, payment or account came from. The question is narrow and tied to the funds in front of you: the amount being transferred, the capital being introduced or the premium being paid.
Source of Wealth: the whole picture
How a person or entity accumulated their total wealth over time — the sum of their assets, not one payment. It is the broader question and usually requires a short, coherent narrative supported by documents.
When you are likely to be asked
During onboarding, when a relationship moves into enhanced due diligence, when a transaction is large or unusual for the customer profile, when a customer is a politically exposed person, or when a higher-risk jurisdiction is involved.
Documents that usually answer Source of Funds
Bank statements showing the incoming transfer, a sale or redemption confirmation, a loan agreement, a dividend statement, a solicitor's or notary's confirmation, or payslips where the funds come from salary.
Documents that usually answer Source of Wealth
Employment contracts and salary history, annual tax returns, audited financial statements, business sale agreements, inheritance or gift documentation, property records and investment statements. For a company, expect a group structure or ownership chart alongside the UBO details.
What makes a file move faster
Give a short chronology in the customer's own words and attach the document for each step. Explain gaps rather than leaving them. Keep names, dates and amounts consistent across documents, and have non-English documents translated. Where a document cannot be provided, say so and offer the closest alternative.
For firms handling the request
Asking for the right thing the first time is the difference between a file that closes and one that sits. A clear internal standard for what counts as Source of Funds and Source of Wealth evidence, recorded consistently, reduces remediation work later.
How we can help
We support banks, fintechs and other organisations with KYC, CDD and EDD files, Source of Funds and Source of Wealth review, UBO analysis and onboarding — as project capacity or on individual files. See our compliance and AML service, or contact us.
This content is general information and does not constitute legal advice. For advice on your specific situation, please contact us.
