As part of due diligence, we establish the Source of Funds for all clients. For higher-risk relationships, especially PEPs and CEPs, we also verify and document the Source of Wealth. This information must stay current and accurate. Transactions should always match what we know about the client.

• Source of funds: Where did the money for this transaction come from? It refers to the origin of the specific funds used in a relationship or transaction and the path those funds took into the account. Examples include salary, sale proceeds, dividends, loans, or gifts, with evidence tied to this payment.
• Source of wealth: This explains the client’s wider financial story—how they acquired their total wealth. It covers the economic activity that generated the wealth over time and the supporting evidence. Examples include long-term earnings, business sale proceeds, investments, or inheritance. We take reasonable steps to evidence this, and for higher-risk cases and PEPs, it is mandatory.

These terms are not interchangeable. You need proportionate and reasonable measures for each, based on risk. If funds come from a third party, you must confirm that party’s Source of Funds. For higher-risk cases, especially PEPs and CEPs, you must go deeper on both.