Source of Funds Checks: Evidence and Scrutiny for Law Firms
Collecting bank statements is one part of a source-of-funds investigation. The file should also explain the proposed funding, assess the supporting evidence and record how material inconsistencies or changes were addressed.
These articles examine source-of-funds scrutiny in conveyancing, including gifts, third-party contributions, changed payment arrangements and the quality of internal file reviews.
Do your files explain where the money came from?
An independent AML audit can examine whether the funding explanation, evidence and recorded decisions support one another, and whether changes were recognised at the appropriate stage.
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Your Conveyancing AML Policy Quotes the Law. Does It Explain the Job
The article emphasizes the need for tailored anti-money laundering (AML) documentation within conveyancing firms, highlighting gaps between policy wording and practical application. It encourages clear procedures that specify roles, actions, and documentation requirements to ensure compliance and effective monitoring. Independent audits can help address discrepancies in understanding and implementation of AML processes.
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Does Your AML File Review Actually Test Source of Funds?
“Source-of-funds documents on file: yes.” What does that answer actually establish? It may confirm that bank statements were collected. It does not explain whether anyone investigated the money’s origin, considered unusual entries or reached a reasoned conclusion about the funds being used for the purchase. The SRA’s guidance on AML policies, controls and procedures, published…