Source of Funds & Source of Wealth Workflow
Why this matters
Property transactions involve large sums. Establishing where the money comes from — and how the client built that wealth — is a core AML requirement.
Poor source of funds documentation is one of the most common SEPBLAC inspection findings in the real estate sector.
Practical implementation
Source of funds (SoF)
The specific origin of the money used in this transaction — e.g. salary, business income, asset sale, inheritance, mortgage, investment proceeds.
Source of wealth (SoW)
The broader origin of the client's overall wealth — relevant for high-net-worth clients, EDD cases and complex structures.
Evidence
Bank statements, payslips, sale contracts, tax returns, dividend confirmations or accountant letters — appropriate to risk and amount.
Review
Compare what the client says with what the documents show, and document any gaps or follow-ups.
How PropComply helps
- Structured SoF and SoW document requests sent directly to the client.
- Categorised storage of evidence by source type and transaction.
- Review workflow with documented analyst conclusions.
- Reusable across future transactions for the same client when appropriate.
PropComply supports — but does not replace — professional judgement, and does not guarantee AML compliance. Each obligated subject remains responsible for its own AML decisions.
Practical example
A buyer funding the purchase from a business sale
A buyer states the €1.2M purchase will be funded from the recent sale of a tech company.
PropComply collects the sale contract, the bank statement showing receipt of the proceeds, and a recent tax return showing consistent business income.
The file documents the reviewer's conclusion that the stated SoF is plausible and evidenced.
Best practice
- ·Match the depth of SoF documentation to the risk and value of the transaction.
- ·Do not accept verbal explanations as evidence.
- ·For high-value or complex cases, document SoW in addition to SoF.
Related guides
Enhanced Due Diligence in Practice
How higher-risk clients should be handled and how PropComply supports Enhanced Due Diligence in real estate transactions.
How PropComply Performs Customer Due Diligence
The complete KYC and CDD workflow supported by PropComply — identification, verification, screening and documentation.
Real Estate AML Risk Assessment
How client risk scoring and transaction risk assessment work inside PropComply.
Need help implementing your AML framework?
CostaAML Compliance provides AML implementation, training, documentation and regulatory support for Spanish real estate professionals.
Learn about CostaAML ComplianceNeed an operational AML platform?
PropComply helps digitise customer due diligence, onboarding and AML documentation for Spanish real estate.
Book a PropComply Demo