Source of Funds and Source of Wealth

Where a PEP relationship exists, Keystone must take adequate measures to establish both source of funds and source of wealth.

The responsible lawyer should therefore ensure there is a clear and documented understanding of:

• the origin of any funds connected to the matter;
• how the client accumulated their wider wealth;
• whether the source of that wealth is consistent with their known background and activities; and
• whether there is any indication that assets may have been derived from corruption, misuse of public office or other criminal conduct.

The extent of the enquiry should always be proportionate to the level of risk presented.

The responsible lawyer should be able to explain not only what information was obtained, but why it provides reasonable comfort that the wealth and funds involved are legitimate.