Category: Compliance & AML · Reviewed by Mark Fox, Broker · Renewals · Last reviewed June 2026
The origin of the customer’s overall accumulated wealth — covering business activities, employment history, inheritances and other significant accumulations — evidenced where Enhanced Due Diligence is required.
Source of Wealth (SoW) is the origin of the customer’s entire accumulated wealth pool. It is the bigger-picture context that explains how the customer came to be in a position to hold their current net assets and to fund significant transactions. SoW differs from Source of Funds (SoF), which is focused on the specific money behind a particular transaction.
MLR 2017, regulation 35 (PEPs — explicit SoW requirement) and regulation 33 (additional measures in higher-risk situations). JMLSG Guidance Part I, chapter 5.5 expands on practical application.
SoW evidence might include audited business accounts over time, sale-of-business documentation, inheritance grants, property sale records, employment compensation history (P60s, P11Ds), professional CV / LinkedIn profile, news reports of significant transactions or appointments. The objective is to construct a coherent narrative consistent with the customer’s economic standing. Where the narrative does not match observable indicators, EDD escalation and SAR consideration follow.
SoW is principally required for PEPs and for any higher-risk situation where the firm’s risk assessment justifies it. SoW is more burdensome to evidence than SoF and is calibrated to the risk. Some institutions accept self-declaration of SoW supported by corroborating evidence rather than full documentary trace for moderate-risk relationships.
A PEP’s SoW might be documented by reference to the PEP’s career history, public reports of their salary as a public official, professional positions held before public office, family inheritance documentation, and evidence of the family business. The narrative is captured in writing on the customer file with supporting documents.
Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (S.I. 2017/692), regulations 33 and 35. JMLSG Guidance Part I, chapter 5.
By Matt Bartlett, Director, on 2026-06-11.
This entry is part of the Apex Insurance Wiki. Last reviewed by Matt Bartlett on 2026-06-11. Apex Insurance Brokers Limited, FCA FRN 724952, Companies House 07014570. Not regulated advice — consult your broker on your specific position.
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