Source of Funds

Source of funds concerns the specific funds being used in connection with a matter.

The relevant question is: How did the person providing the funds obtain the money that is being used in this matter?

This requires consideration of the true origin of the funds and not simply the account from which payment is received.

For example:

• a bank account is not itself a source of funds;
• a solicitor's client account is not itself a source of funds;
• an investment platform is not itself a source of funds.

The lawyer should instead understand the underlying activity that generated or accumulated the money ultimately reaching Keystone or being used in the transaction.