Source of Wealth and Source of Funds Checks with OSINT
A source of wealth check asks one question: does the customer's account of how they became wealthy hold up against records nobody in the relationship created? We rebuild the career, companies, sales and property behind the declared story and show where the record agrees, is silent or contradicts it.
- Business sales and exits
- Property and inheritance events
- Career and salary plausibility
- Gaps listed for your MLRO
A source of wealth check corroborates how a customer built their total net worth, while a source of funds check looks at where the money for this specific relationship comes from. OSINT-S tests both against company registers, filings, property records, court files and media, builds a dated timeline and lists discrepancies. Your firm weighs the evidence and makes the decision; we never contact the customer.
Source of Wealth vs Source of Funds
Source of wealth is the origin of everything the customer owns; source of funds is the origin of the money moving through this account. A check usually needs both.
The FATF guidance on politically exposed persons draws the line clearly. Source of wealth "refers to the origin of the PEP's entire body of wealth (i.e., total assets)", and source of funds "refers to the origin of the particular funds or other assets" that are the subject of the business relationship (FATF PEP guidance, paragraphs 87 and 88).
In the UK, a firm that has or continues a relationship with a PEP, a family member or a known close associate must "take adequate measures to establish the source of wealth and source of funds" (MLR 2017, regulation 35). FCA guidance adds that for lower-risk PEPs firms may rely on information they already hold, such as transaction records or public information, while higher-risk cases call for "more intrusive and exhaustive steps" (FCA FG17/6, paragraphs 2.35 and 2.36).
Common Wealth Stories and What the Public Record Can Show
Each type of declared wealth leaves a different trail. Some can be corroborated well from open sources; others mostly need documents from the customer.
| Declared source | Public records that can corroborate it | What usually still needs documents |
|---|---|---|
| Sale of a business | Company filings before and after the sale, shareholder changes, deal announcements, trade press, the buyer's own filings | Sale agreement and the customer's share of the proceeds |
| Property | Land and title registers where they are public, planning records, mortgage and charge entries, sale listings | Completion statements and rental income |
| Inheritance | Probate records where available, obituaries and notices, the deceased's own companies and property | Will, grant of probate and estate accounts |
| Salary and bonuses | Career history, board appointments, published executive pay in annual reports, industry pay ranges | Payslips, tax returns, bonus letters |
| Investments | Shareholdings in company registers, listing disclosures, dividend history | Brokerage and custody statements |
For property in England and Wales, the title register shows "who owns the property or land" (HM Land Registry); other countries range from fully public registers to none. When the trail shows assets the customer did not mention, a real estate and property search can follow them further.
Red Flags in a Source of Wealth Check
The strongest red flags are mismatches of time, scale and role: wealth that appears too early, too fast or out of proportion to the business behind it.
- The timeline does not fit. The company said to have been sold in 2015 was still filing accounts under the customer's ownership in 2019, or was dissolved without a buyer.
- The scale does not fit. Filed revenue or net assets make the claimed sale price implausible, or a salary story would need decades at a level the role never paid.
- Wealth grew during public office. Assets acquired while the customer or a relative held a public role, especially where the declared income was a public salary. Our PEP and adverse media screening establishes the role and its dates.
- Someone else holds the assets. Property or companies registered to relatives, nominees or offshore vehicles that the customer controls. FATF lists the "use of family members or close associates as legal owner" as a red flag (FATF PEP guidance, Annex 1).
- The public story changed. Interviews or earlier filings describe a different origin for the money.
A red flag is a question for the customer, not a conclusion; the file says which documents would settle each one.
How an OSINT Source of Wealth Check Runs
Five steps, from the customer's declaration to a dated timeline with every claim marked as corroborated, unverified or contradicted.
- Share the declarationYou send the customer's account of their wealth and only the identifiers the case needs.
- Agree scope and dateWe confirm the countries, the depth and the delivery date in writing and send a fixed quote.
- Rebuild the timelineCareer, directorships, shareholdings, transactions, property and family events go on one dated timeline.
- Test each claimEvery element of the declared story is marked corroborated, unverified or contradicted, with the source and a confidence level.
- Senior review and deliveryA senior analyst reviews the file before your team receives it, with captures of each source for your records.
What OSINT Can and Cannot Show About Wealth
Open sources test plausibility and consistency. They do not see bank accounts or tax returns, and they never replace the evidence your firm collects from the customer.
- Your firm decides. We do not approve customers, set risk ratings or decide whether something is suspicious. The file is evidence your MLRO weighs alongside the customer's documents.
- No private financial data. No bank statements, tax records or leaked data; only public and lawfully licensed sources.
- No contact. We never approach the customer, their family or their former business partners. In the UK regulated sector, disclosures likely to prejudice an investigation can be a tipping-off offense (POCA 2002, s.333A).
- Silence is not proof. Many legitimate fortunes sit in private companies or closed registers; where the record is thin, we say so.
The OSINT Wealth Report: Format and Timing
A timeline, a claim-by-claim table and a list of documents to request, delivered from 10 business days for a focused check.
The report opens with the answer: is the declared story consistent with the public record? Then come the timeline, the claim table, any undisclosed assets and the questions to put to the customer. A single liquidity event can be checked from 10 business days; wealth spread across several jurisdictions and structures can take up to about a month. Urgent files cost 50% more, the quote is fixed after written scoping, and if we miss the agreed date the fee goes down.
Where ownership runs through holding companies or trusts, the check works alongside beneficial ownership investigations, and a full onboarding file sits within enhanced due diligence. Source of wealth work is one of the OSINT services for compliance teams that OSINT-S runs under NDA.
Send Us the Wealth Story You Need to Test
Share the customer type, the declared sources of wealth, the countries involved and your deadline. We reply with a scope, a delivery date and a fixed quote.
Source of Wealth Check FAQ
Our private bank needs a source of wealth check on a new client who says he made his money building and selling a software company — what can you confirm without asking him for anything?
Usually a lot. We can trace the company through its filings, confirm his roles and shareholding over time, find the sale in announcements, trade press and the buyer's records, and compare the timing and scale with his property and later investments. The file shows what is corroborated and which documents, such as the sale agreement, only he can provide.
Our prospective client says her wealth comes from an inheritance from her grandfather — how do you corroborate an inheritance from open sources when probate records are not public in that country?
We look at the grandfather himself: the companies he owned, the property registered to him, his career and any notices of his death. If he plainly had substantial assets, the story is plausible even without probate records. If he leaves no trace at all, that gap goes in the file as a question, and the will or estate accounts become the documents your team should request.
We're an e-money firm and a customer is depositing funds from a property sale abroad — is that a source of funds question or a source of wealth question, and do we need both checked?
The deposit itself is a source of funds question: did this property exist, did the customer own it and was it sold around that date? How the customer came to own it is a source of wealth question. For a PEP, UK rules require measures on both.
My MLRO wants to know whether your report will say the customer is clean or not — do you give an opinion on whether we should onboard someone after a source of wealth review?
No. We report what the public record shows: each claim marked as corroborated, unverified or contradicted, with sources and confidence levels, and the open questions. Whether that is enough to onboard, what risk rating to apply and whether anything is suspicious are decisions for your firm.
We have a high-net-worth client with assets across four countries and a family trust — how long does a full source of wealth check take, and can you do it faster for a deadline?
A spread like that typically takes up to about a month, because each country's registers and each layer of the trust need their own research. A focused check on one main liquidity event can start from 10 business days. Urgent delivery is possible for 50% more, and the agreed date is fixed in the quote, with a lower fee if we miss it.
Sources and Notes
- FATF Guidance: Politically Exposed Persons (Recommendations 12 and 22), paragraphs 87–88 and Annex 1
- UK Money Laundering Regulations 2017, regulation 35 (politically exposed persons)
- FCA FG17/6: The treatment of politically exposed persons for anti-money laundering purposes
- GOV.UK / HM Land Registry: Get information about property and land
- Proceeds of Crime Act 2002, section 333A (tipping off)
Sources checked 8 October 2026. Figures about third-party firms and tools are as published by them or by the cited source on that date.