Understanding the Source of Wealth (SoW) of our clients is a critical step in managing financial crime risk. SoW refers to the origin of a client’s entire body of wealth (i.e., total assets). SoW describes the economic, business and/or commercial activities that generated, or significantly contributed to, the client’s overall net worth/entire body of wealth. This should recognise that the composition of wealth generating activities may change over time, as new activities are identified, and additional wealth is accumulated.
SoW examples include family inheritances, investments, business ownership, and income from employment.
You are expected to investigate and satisfy yourself that the clients’ reported income and wealth aligns with the documentation and information they have provided. For example, does their income and wealth correlate with their job role? Information should be verified with evidence, rather than simply taking clients’ assertions or making assumptions based on clients’ profiles. The extent of the evidence required to verify the source of the funds or wealth will vary from case to case and will also depend on your assessment of risk in the circumstances.
The form is to be completed by the client. Notwithstanding that the front two pages are directed to the lawyer, the declaration form is to be completed by the client. It is for the firm to set out an explanation as to the need to complete the form. This document does not provide any advice to the underlying client
