The AML Clinic Podcast

How not to conduct source of funds checks - A Cautionary Tale from the SDT

Michelle Clement

In this episode of The ANL Clinic, we dive into one of the most critical and often misunderstood  areas of financial crime prevention: the difference between source of funds and source of wealth.

We explore a real Solicitor Disciplinary Tribunal case involving a politically exposed person, a £1.1 million transaction and a £1.9million transaction, and serious gaps in due diligence.

Key takeaways:

  • Why distinguishing source of funds vs source of wealth matters
  • The risks of relying on third-party assurances
  • How compliance failures can lead to disciplinary action

SRA | Thematic review of source of funds and wealth compliance | Solicitors Regulation Authority