Source of Wealth: Ask the Story Before Asking for the Documents

Source of wealth reviews can become unnecessarily inefficient when the process begins by requesting documents before understanding the underlying story.

A better starting point is often the narrative.

How was the client's wealth accumulated? Over what period?

• employment
• business ownership
• investment
• inheritance
• asset disposal
• multiple sources

Once that story is understood, the compliance professional can determine what information or evidence is relevant.

Questionnaires should adapt

An intelligent source-of-wealth questionnaire should therefore adapt to the client's answers. For example, selecting business ownership should trigger questions about:

• business activity
• ownership percentage
• period of ownership
• approximate value
• distributions or sale proceeds
• relevant supporting information

An inheritance pathway requires an entirely different set of questions.

The objective is not to create the longest possible questionnaire. It is to collect enough structured information in the first interaction to understand the wealth narrative and identify what needs verification.

Note on sources: This article is practitioner commentary and not definitive regulatory guidance. Source of wealth and source of funds expectations should be applied in line with applicable regulatory requirements and your organisation's own risk-based procedures.