Source of Wealth Evidence: Examples for Inheritance, Business Sales and Investments

Source of wealth evidence should explain how a customer acquired their wealth and connect that explanation to reliable records. For inheritance, that may mean succession and distribution records. For a business sale, it may mean ownership, completion and net-proceeds evidence. For investments, it may mean the original capital, portfolio history and returns.

The useful question is what each record establishes and what remains unexplained. A will can identify a beneficiary without showing a distribution. A sale announcement can confirm a deal without showing the seller’s personal proceeds. A portfolio balance can show assets without explaining how the customer funded them.

This guide is for bank KYC reviewers, relationship managers and compliance teams selecting evidence for a file.

For an existing client book, our source of wealth remediation guide for banks explains how to prioritise legacy files, reuse adequate evidence and distinguish current updates from possible historical failures.

Written by AgentKYZ. Sources checked: 31 October 2026. The evidence combinations and numerical examples below are illustrative working examples, not customer cases, regulatory forms or assurances of acceptance. Apply current local requirements and your bank’s approved policy.

Source of wealth vs source of funds

Source of wealth (SoW) explains the activities and events that generated the customer’s overall wealth. Source of funds (SoF) explains the origin of the money or assets used for a particular transaction or banking relationship, including the relevant transfer route. The Wolfsberg FAQs, questions 1 and 5–7, distinguish these enquiries and recognise that evidence can overlap.

A founder might have accumulated wealth by building and selling a company. The source of funds for today’s deposit might be the redemption of investments bought with those sale proceeds. The file needs to connect those events when relevant; “from another bank” describes a route, not the underlying economic source. AUSTRAC makes that distinction explicitly.

Do not count the same wealth twice. Sale proceeds reinvested in a portfolio are not two separate contributions to net worth. Separate the original capital from later additions, income, gains, losses and withdrawals.

Source of wealth documents at a glance

The table is a starting point for evidence selection. It is not a minimum pack or a list of automatically acceptable documents. AUSTRAC’s evidence examples include probated wills, investment statements, sale agreements, share-register extracts and professional confirmations. The combinations and limitations below are our practical application of those examples and the ACIP corroboration guidance, section 4.2.

If the table is wider than your screen, scroll across. Keyboard users can focus the table and use the arrow keys.

If these gaps recur across a backlog, AgentKYZ’s managed KYC service can scope evidence review and remediation under your approved policy. Your authorised team keeps the acceptance and approval decisions.

Inheritance: entitlement, distribution and underlying wealth

Start with the deceased person’s identity, their relationship to the customer, the relevant jurisdictions, the date of death and what the customer says they inherited. Distinguish a cash distribution from inherited property, securities or an interest held through a trust.

Possible evidence serves different purposes:

• A will, grant of probate, letters of administration or applicable local succession record may establish entitlement or authority to administer the estate. Check what that particular document actually establishes.
• Estate accounts or an executor’s distribution statement can explain the assets, liabilities, expenses and allocation among beneficiaries. The gross estate value is not necessarily the amount available for distribution.
• Confirmation from the executor or legal practitioner can identify the customer, the assets or amount distributed, dates and the records relied on. Assess the issuer’s role and basis of knowledge; a letter repeating the customer’s account adds little corroboration.
• Bank credits or securities, land or other asset-transfer records can connect the distribution to the recipient. Reconcile multiple payments and any intermediate estate, solicitor or trust account.

Worked example: estate accounts show a net distributable estate of £6 million and the customer’s 25% entitlement, or £1.5 million. Two documented distributions of £1.2 million and £300,000 reconcile to that entitlement. A file citing only the £6 million estate valuation would overstate the customer’s inheritance. If the current claimed wealth is £3 million, the reviewer still needs to understand the subsequent accumulation or other sources.

Receiving an inheritance does not answer every question about its origin. ACIP section 4.2.1, printed pages 15–18, discusses the asset contributor’s background, the plausibility of the amount and difficulties with older records. Consider the deceased person’s business, employment or investment history in proportion to the risk and applicable requirements. A material unexplained estate, relevant adverse information or an implausible amount may require deeper corroboration.

Do not insist on a document that the relevant legal process never produced. GOV.UK’s probate guidance explains that probate is not always needed and that Scotland and Northern Ireland have different rules. Elsewhere, succession may be evidenced through different courts, notaries or registries. Establish the local equivalent with appropriate advice. A death certificate alone does not prove the beneficiary’s entitlement or the value received.

Business sales: reconcile the deal to personal proceeds

Ask what was sold, who owned it, who bought it, when completion occurred and who received the consideration. A shareholder selling shares and a company selling its assets produce different evidence chains. Do not attribute a company’s asset-sale proceeds to an individual solely because they hold shares. Establish whether and how proceeds were lawfully paid or distributed to the shareholder, with evidence for any dividend, liquidation distribution or other transfer.

An evidence review may combine:

• Ownership and acquisition history: historical share registers, corporate filings, subscription or acquisition records and documents explaining nominee or holding-company arrangements. A current register may no longer show the former owner.
• The transaction and completion: the executed agreement, relevant amendments, closing or completion statement, and independently sourced buyer announcements or filings where available. Signing an agreement does not establish completion.
• The customer’s proceeds: the actual allocation among sellers and share classes, debt and cash adjustments, fees, escrow, rollover equity, deferred consideration and earn-out terms, matched to receipt records.
• The business behind the value: financial statements, operating history and independent information appropriate to the business and period. Tax records can support declared proceeds or gains, but check what they establish and whether they reconcile to the transaction.

Worked example: a deal is announced at £20 million enterprise value. Assume £4 million net debt, one share class and pro-rata rights with no other price adjustments. Equity proceeds are £16 million; a 30% shareholder’s allocation is £4.8 million. If £600,000 of that allocation remains in escrow, the immediate receipt is £4.2 million before any further personal costs or tax. The £20 million headline is not the customer’s cash wealth. Use the actual agreement and distribution waterfall, not these simplifying assumptions.

Keep contingent earn-outs and retained shares separate from cash received. Reconcile foreign-exchange conversions, payment dates and third-party payers. Where proceeds passed through a holding company, establish the customer’s entitlement and the transfer out of that company rather than assuming beneficial ownership gives unrestricted personal access to every company asset.

ACIP section 4.2.2, printed pages 18–19, discusses valuation difficulties and a case where a sale agreement did not resolve concerns about a business’s sale value. A price far above an appropriate benchmark may have a commercial explanation; it still needs examination. Related-party deals, unexplained ownership changes or conflicting financial records call for focused follow-up, not an automatic conclusion of wrongdoing.

Investments: trace the capital and separate returns from deposits

“Investment gains” should identify the investments, ownership, period and scale. A recent portfolio screenshot does not show whether the customer earned the balance, inherited it, borrowed against assets or transferred it from another account.

For listed securities or managed portfolios, consider historical custodian or broker statements showing the account holder, opening and closing values, contributions, withdrawals, income and transactions. Contract notes and tax statements may help explain significant disposals. For a private fund, subscription and capital-call records, capital-account statements and distribution notices may be more useful. Identify who issued the records and what periods and entities they cover.

Worked example: a portfolio starts at £2 million, receives £800,000 in new contributions and pays out £300,000. It ends at £3.1 million. The net investment result is £600,000: £3.1 million − £2 million − £800,000 + £300,000. This reconciliation assumes consistent valuation boundaries and includes valuation movements and charges reflected in the account. It is not an annualised return calculation. The reviewer must still explain the £2 million starting capital and the £800,000 added, to the extent required by risk and the applicable framework.

Avoid treating transfers between the customer’s own portfolios as new wealth. Distinguish realised proceeds from unrealised gains, cash distributions from reinvested income, and asset values from liabilities such as margin loans. For a proposed deposit funded by a sale or redemption, link that event to settlement and the payment received.

Historical market prices can test whether a claimed return is plausible. They do not prove that the customer owned the security during that period. ACIP section 4.2.3, printed pages 20–21, warns about narratives built with hindsight around successful investments and suggests historical portfolio evidence. Explain unusual returns with the actual holdings, dates and relevant risk or borrowing, rather than applying an index return to an unsupported starting amount.

Risk-based corroboration and jurisdiction differences

Corroboration means supporting a customer’s explanation with information independent of that explanation. The Wolfsberg FAQs, question 4, emphasise the source, type and verifiability of evidence. Customer-supplied records may have been issued by an independent institution; conversely, several websites repeating the same press release are not several independent confirmations.

Select evidence against the unresolved fact. Consider reliability, independence, coverage of the relevant period, authenticity concerns and consistency with other records. Verify a professional’s identity and role through a reliable channel when needed. A certification may address a copy’s authenticity without confirming the truth of the underlying wealth explanation.

The depth of review depends on the customer, beneficial owners, geography, business activity, products, transaction pattern and relevant politically exposed person (PEP) or adverse-information findings. ACIP’s materiality, relevance and prudence principles, printed pages 3–4, provide a useful framework: focus on material or higher-risk sources, seek fit-for-purpose evidence and be cautious with assumptions. Initial capital can matter because it enabled later wealth, even if it is now a small percentage of the total. Do not use a percentage target to disregard a smaller, higher-risk wealth source.

Keep the authority and geographical scope clear:

• Singapore: ACIP’s May 2025 paper is industry best practice, not additional legal requirements. Section 3.1 describes source-of-wealth establishment and corroboration for private-banking and wealth-management customers and their beneficial owners. Apply the relevant MAS requirements alongside it; do not carry a lower-risk retail approach into private banking without checking the applicable expectations. Our MAS AML requirements guide for fund managers and VCCs covers those entities, not a bank-specific checklist.
• United Kingdom: Regulation 35(5) requires adequate measures to establish relevant source of wealth and funds for PEP relationships covered by the provision, alongside senior-management approval and enhanced monitoring. Regulation 35(3A) gives domestic PEPs and their family members and known close associates a lower-risk starting point than non-domestic PEPs, with less extensive enhanced due diligence (EDD) absent additional enhanced risk factors. This does not remove the required measures or make PEP status evidence of misconduct.
• Australia: AUSTRAC’s guidance distinguishes collecting information from verifying it and calls for verification appropriate to risk. Its examples and circumstances requiring checks apply within the Australian framework, not as a global bank-document standard.

For cross-border records, assess local succession and company law, registry coverage, language and access restrictions. Obtain a suitable translation where needed and retain the source record. The country of the receiving bank alone does not determine the legal meaning or reliability of every document in the file.

When older documents are unavailable

Record the missing fact and attempts to retrieve evidence before deciding on an alternative. Depending on the case, alternatives might include archived registry filings, historical account records already held by the bank, estate records, credible contemporary reporting or confirmation from a professional with access to the underlying records. Explain what each source supports and its limitations.

Wolfsberg questions 4 and 10 address generational wealth and older inheritances where corroboration is difficult: assess plausibility, seek support for significant milestones and document exceptions and governance. ACIP likewise cautions that benchmarks alone should not be mistaken for corroboration. A relationship manager’s knowledge can add context but should not silently replace required independent evidence.

An old date does not make a document useless, and a missing document does not by itself establish wrongdoing. Equally, lack of records is not permission to accept an unsupported narrative. Record unresolved risk, escalation and any permitted compensating controls. An internal exception cannot waive a legal requirement. Handle possible suspicion through the appropriate restricted reporting process rather than waiting for a routine remediation deadline.

A reviewer’s source of wealth evidence checklist

Before recommending a decision, check that the file answers these questions:

1. Whose wealth is being assessed? Identify the customer, relevant beneficial owner or asset contributor, and the applicable legal entity and policy.
2. What generated it? Record the activities, dates, countries, approximate amounts and material changes. Separate customer statements, documented facts and estimates.
3. Why does it belong to this person? Connect ownership, entitlement and any intermediate company, estate or trust to the customer.
4. Do the amounts reconcile? Distinguish gross values, liabilities, net entitlements, cash received and assets still held. Explain material differences without double-counting reinvested capital.
5. What does each source support? Index the issuer, date, document location, relevant page or transaction and the fact corroborated. Record authenticity or independence concerns.
6. What remains unresolved? Name the missing evidence, why it matters, the action owner and the escalation or approval needed. Document the basis for any acceptable residual risk.
7. Does the current funding fit? Assess the transaction’s source of funds separately, reusing relevant evidence where appropriate. Record the reviewer’s rationale and the authorised decision.

Use this checklist for evidence selection. It does not replace customer acceptance, enhanced due diligence, sanctions checks or ongoing monitoring.

For legacy-file closure, see what a completed source-of-wealth remediation file should contain, including the evidence index, unresolved exceptions, approvals and handover to monitoring.

Scope source of wealth file work with AgentKYZ

AgentKYZ’s managed KYC service supports onboarding, remediation and periodic reviews under your approved AML policy. Agents organise evidence and perform the first pass; qualified compliance reviewers check the work. For source-of-wealth cases, agree the narrative, evidence-index, reconciliation and exception-log deliverables before work starts.

Bring your case count, jurisdictions, wealth-source mix, known evidence gaps and target date to a scoping call. Agree who contacts clients, which cases require specialist input, the review standard and how unresolved concerns reach your team. Your firm retains compliance responsibility, customer acceptance, required approvals and reporting decisions. Share customer documents only through the agreed secure channel after the scope and data-handling terms are settled.