Source of funds and wealth

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As lawyers we are required by law to be vigilant about terrorist financing, money laundering and suspicious financial activity.  In England and Wales we must complete source of funds and wealth checks for our clients to ensure that funds do not come from any of these sources. This policy outlines how Argo handles and verifies the source of funds and wealth investigations we need to make in line with our obligations under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, the Proceeds of Crime Act 2002 and with the requirements of CRL, our regulators, and any other relevant UK legislation or guidance that we must follow.

Investigating a client’s source of funds and wealth isn’t just about ticking boxes, it’s about protecting our clients, maintaining ethical standards, and ensuring our firm remains a safe and transparent place to do business.

 

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What do we mean by source of funds and source of wealth?

“Source of funds” refers to where the money being used in a transaction comes from, for example, is it from your savings, a house sale, an inheritance, or something else?

This is different from “source of wealth,” which relates to how your overall assets were accumulated over time.  It is a broader understanding of where your assets have come from.  It includes all your wealth, assets, income and  other financial resources.  These checks are carried out to understand your financial background and assess the risk associated to the transaction.

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We are required to ask for evidence of your source of funds and your source of wealth.  This means we need to find out where money has come from to fund the specific transaction you are completing with us and how you have accumulated your wider wealth.

 

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Why we need this information

As a regulated law firm, we are required to:

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• Identify and verify our clients;

• Understand the nature and purpose of the business relationship; and

• Confirm that the funds used in any transaction are legitimate.

 

This is especially important for property purchases, large payments, gifts, estate distributions, or any transaction involving significant financial movement.

 

 

What we might ask for

Depending on the transaction, we may request:

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• Bank statements showing funds being built up or received.

• Pay slips if funds are from employment.

• Sale completion statements if funds come from a property or other asset sale.

• Inheritance paperwork if the funds are from an estate.

• Loan agreements if funds are borrowed from a third party.

• Gift letters (including ID of the person gifting the money and evidence of their source of funds)

• Cash payment evidence ie bank statements to show where cash came from

• Property ownership documents

• Investment portfolio documents

• Business ownership documents

• Tax returns

• Trust documents

• Loans from a third party (including ID of the person gifting the money and evidence of their source of funds).

 

We’ll always explain clearly what we need and why, and we aim to be as straightforward and supportive as possible.  This list of what is acceptable is not set in stone and will vary upon several factors and concerns.

 

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Identification

We identify each client at the outset of their case by asking that they produce original or certified copies of photographic ID and proof of address as detailed in our correspondence and instruction form.

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In some cases we may deem it necessary to carry out an electronic identification check against you and in addition to the usual identification requirements.  By instructing us, you are providing your consent to an identification check being carried out again you.

 

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How we handle your information

All documents and information provided will be treated as confidential and stored securely in accordance with data protection laws and our firm’s privacy policy. We never share your documents without your permission unless required to by law.

 

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When we might decline to proceed

Every firm is different when it comes to diligence checks, depending upon their attitude to and their experience in dealing with transactions.  Every transaction is also different.  We reserve the right to refuse to act if:
 

• We are not satisfied with the evidence of source of funds;

• We believe the funds may be linked to criminal activity; or

• You refuse to provide the necessary documents.

 

 

Need help? Just ask.

We understand that gathering paperwork can be daunting, especially at an emotional or stressful time. Our team is always here to explain what’s needed and help you through the process with empathy, clarity, and respect.