As part of Know Your Customer (KYC)/Customer due diligence (CDD) requirements under the MLR 2017 Regulation 35; 5b, obliged entities are required to establish the Source of Wealth (SoW) and Source of Funds (SoF) of all clients, i.e. they must evidence how clients have acquired the funds they will be putting into their accounts or the deposits they hold on their behalf. Firms must be satisfied that the funds held on behalf of clients are consistent with the risk profile of the client without raising any suspicions to money laundering or any other financial crime. This must be done at onboarding and also as part of ongoing client lifecycle management using the risk-based approach.

On the August 7, 2020 the Wolfsberg Group as part of its mission to develop frameworks and guidance for the management of financial crime risks, particularly with respect to KYC, Anti-Money Laundering and Counter Terrorist Financing policies, published a guidance on SoW and SoF for Private Banking/Wealth Management clarifying issues around establishing clients SoW & SoF. Click here to read the guidance.

How We Can Help Firms Succeed

  • For foreign owned banks and regulated businesses in the UK with clients and business links in Ghana and other Sub Saharan African countries, we can support you to comply with the stricter Enhance Due Diligence (EDD) requirements on your clients and transactions (new foreign accounts for public and private sector entities, correspondent accounts, PEPs, High-Net Worth Individuals, and Trade Finance-related due diligence – LCs and Guarantees).
  • Our due diligence reports will help your business to identify and minimise potential business risks and ensure that your business meets its legal and regulatory obligations.
  • All our KYC/EDD reports are customised to the requirements of the prospective clients.
  • For accountable institutions in Ghana and other regulated businesses in Sub Saharan African Countries, we are here to support you with your AML and Financial Crime Compliance Needs: Audit Review of your Financial Crime Systems and Controls and Compliance and bespoke Financial Crime Compliance Trainings.
  • Speak to us today and we will offer you a competitive price.

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