Source of funds and source of wealth are two important verification steps a firm can take to identify potential money laundering activities or other financial crime.
The Money Laundering Regulations 2017 (MLR 2017) require firms, where necessary, to scrutinise the source of funds of a transaction to ensure they are consistent with their knowledge of the customer, their business and risk profile. In addition, where a matter is considered to be higher risk and therefore subject to enhanced due diligence, firms must also investigate the client’s overall source of wealth.
Law firm staff must be able to differentiate between source of funds and source of wealth, having knowledge of how to verify each and identify any anomalies that do not align with their understanding of the client or the matter. Staff must have the knowledge and confidence to challenge clients and seek further clarification where the source may be unclear or highlight concerns.
A number of firms who failed to sufficiently identify the source of funds and/or source of wealth have recently been fined by the SRA. In the year August 2024 to July 2025, fines in excess of £475,000 were recorded for AML breaches that included source of funds and source of wealth failings.
This course will assist fee earners and support staff in understanding the difference between source of funds and source of wealth, enabling them to capably identify and verify funds in a matter.
Where the SRA has found failings at firms in respect of source of funds or source of wealth, it has almost unanimously also found shortcomings in other areas of AML compliance. Where concerns are raised regarding a firm’s compliance with any aspect of the MLR 2017, the SRA will probe further and look into all areas of AML compliance. For information about DG Legal’s full range of AML training courses, please visit:
https://dglegal.co.uk/training/upcoming-premier-training-courses/.
Target Audience
This online course is suitable for staff of all levels, from support staff to senior partners.
Resources
Comprehensive and up to date course notes will be provided to all delegates which may be useful for ongoing reference or cascade training.
Please note a recording of the course will not be made available.
Speaker
Paul Wightman, Consultant, DG Legal
A qualified barrister, Paul graduated in Law from Birmingham University and was called to the Bar in 1994. He subsequently spent almost 20 years working for the Law Society of England and Wales, initially within the Office for the Supervision of Solicitors, then the Legal Complaints Service (LCS), and ultimately the Solicitors Regulation Authority (SRA). Paul is adept at undertaking audits and providing succinct reports on areas for improvement and can assist firms with advice on all aspects of SRA compliance and Anti-Money Laundering procedures.