When a client presents a high money laundering or terrorism financing risk, you may need to establish their source of funds and source of wealth. This form gives you a simple way to ask, and a record you can keep on file.
Download the form below, add your own branding, and replace the placeholders marked in square brackets before you send it.
The difference between the two
Source of funds is where the money for a particular transaction came from and how the client earned or acquired it. Source of wealth is the broader picture: how the client built up their overall financial position over time. They are separate questions and both are usually needed.
A common mistake is to record the account the money was held in. An account is a location, not a source. If a client writes "my savings account", the question has not been answered — go back and ask how the money got there.
When to use it
This is an enhanced customer due diligence measure. It is not required for every client and there is no dollar threshold. Your AML/CTF Program should set out when you will collect this information, and when you will also verify it. Typical circumstances include:
The client, or a beneficial owner, is a politically exposed person
The client or the funds have a connection to a high-risk jurisdiction
You have assessed the client as high risk and the origin of funds is relevant to that risk
Funds are being provided by a third party, or from a source that is unusual for the client
You have formed, or are likely to form, a suspicion
How to use it
Remove the "Notes for your firm" page. This is internal guidance and should not go to the client.
Apply your branding and complete the placeholders — firm name, matter reference, return address, due date and privacy policy link.
Send it with a short covering note explaining that this is a legal requirement applied to clients in comparable circumstances. Clients respond better when they understand it is not personal.
Return the completed form and supporting documents to the client file.
When it comes back
Check three things before you accept it:
Does it add up? The amounts explained should reconcile to the total involved.
Is it a source, or a location? If the answer only tells you where the money sat, ask again.
Does it fit the client? If the explanation does not match what you know of them, ask more before accepting it.
A completed form is the client's assertion, not proof. Verify it against documents to a degree that matches the risk, and record why you were satisfied. If the explanation does not hold up, escalate to your AML/CTF Compliance Officer.
Where you suspect a client, take care that your questions do not reveal that a suspicious matter report has been or may be made. Disclosure is an offence.
Keeping records
Retain the form by link in your VerifiMe mitigation notes section, the supporting documents and your written assessment shoud be retained for at least seven years, together with a note of who assessed it and what was verified.
Download
This form is a general starting point and is not legal advice. Review it against your own AML/CTF Program and adapt it to your business before use.