Source of wealth corroboration is the work that turns a client's stated wealth narrative into evidence the firm can defend. The FCA expects firms to do more than collect a self-declaration. They expect a proportionate, risk-sensitive evidential chain that links the client's wealth to its origin in a way an external reviewer can follow.
Source of wealth is the question regulated firms get most consistently wrong.
The reason is partly definitional. Source of wealth is not source of funds, though they are routinely confused. Source of funds is the immediate origin of the money used in a particular transaction or relationship. Source of wealth is the broader picture of how the client's overall net worth has been accumulated. The two need different evidence and different documentation, and a file that conflates them is exposed.
The FCA's published guidance, the JMLSG Part I Guidance, and the Wolfsberg Group standards all treat source of wealth as a separate corroboration exercise. In practice, most firms treat it as a tick box on the onboarding form.
Corroboration means the firm has evidence that supports the client's stated source of wealth. The evidence does not have to be exhaustive. It has to be proportionate to the assessed risk and sufficient that a reasonable reviewer would accept the firm's conclusion.
For a client whose wealth comes primarily from a long career in professional services, the evidence might be a CV, employment history, an indication of senior roles held, and an assessment of whether reported income is consistent with the wealth on display. For a client whose wealth comes from the sale of a private business, the evidence is the sale agreement, the post-sale tax position, and an indication that the proceeds match the wealth being managed. For a client whose wealth is inherited, the evidence is documentation of the inheritance and an assessment of the estate's original source.
What the evidence is not is a copy of a passport, a utility bill, and a six-figure number written in a free-text box.
The corroboration burden scales with risk. A standard-risk client whose wealth narrative is unremarkable does not need the same evidential chain as a high-risk client with a complex structure across multiple jurisdictions.
What proportionality does not mean is that the firm gets to do less work on a low-risk file. It means the firm has thought about what evidence is reasonable for the risk assessed, has obtained that evidence, and has documented why that evidence is sufficient. The thinking is what makes the file defensible. A file that contains less evidence than another file is not necessarily weaker, as long as the difference reflects a proportionality judgement that is recorded and reviewable.
Where firms get caught is when proportionality is invoked retrospectively. The file has thin evidence. The reviewer asks why. The firm explains, after the fact, that the client was assessed as low risk and the evidence was therefore proportionate. There is no record of that judgement having been made at the time. The proportionality argument fails because it was reverse-engineered.
I have seen the same set of expectations come up in every supervisory exchange and every Skilled Person review I have worked on or alongside.
The first is that the corroboration exercise is documented as a corroboration exercise, not buried inside a CDD form. The reviewer wants to see what the firm asked, what the client said, what evidence was obtained, what the firm concluded from that evidence, and what residual gaps the firm accepted.
The second is that the evidence is contemporaneous. A 2019 sale agreement is fine if it is the right document. A 2019 sale agreement that the firm never opened until the regulator asked is a different matter. Source of wealth files should show the firm engaging with the evidence, not just collecting it.
The third is that the firm has a documented standard for what counts as sufficient. Two analysts looking at the same client should reach the same conclusion. If they would not, the standard is not a standard. It is an opinion, and opinions do not survive sample testing.
The fourth is that the evidence is refreshed. A source of wealth corroboration done at onboarding in 2020 is not necessarily good in 2026. Material changes in the client's circumstances, in the regulatory environment, or in the firm's risk appetite all create refresh triggers. Files that have not been touched since onboarding are common in wealth management, and they are exactly the files that get pulled in supervisory testing.
Public records are the cheapest and most reliable starting point. Companies House filings, land registry entries, court records, and published financial information are all available without involving the client. Firms that go to the client first, rather than to public sources first, often end up with a corroboration trail that is less robust than it could be, because the client's account becomes the primary evidence rather than independent verification of the client's account.
Client-provided evidence is necessary, but it is rarely sufficient on its own. Tax returns, sale agreements, employment letters, inheritance documentation, all of these have a place. The judgement is whether the document on its face does what the firm needs it to do, and whether the document is consistent with what the client has said and with what is publicly known.
Adverse media and database screening fills the third role. The screening confirms whether the client is associated with anything the firm should know about, and whether the client's stated narrative is consistent with their public profile. Screening that returns clean is not the absence of risk. It is one input into the corroboration judgement.
| Wealth source | Typical evidence chain |
|---|---|
| Employment income | Career history, role seniority, sector benchmarks, public profile consistency |
| Business sale | Sale agreement, Companies House records, post-sale tax position, public reporting |
| Inheritance | Probate documentation, source of the deceased's wealth, estate distribution records |
| Investment returns | Original capital source, investment track record, brokerage statements |
| Property | Land Registry records, original purchase, source of purchase funds, sale proceeds |
None of this is novel. The Wolfsberg Group has been publishing source of wealth standards for two decades. The JMLSG guidance has carried it for nearly as long. What has changed is that the FCA now treats source of wealth as a focal point of supervisory testing rather than a procedural footnote. Firms whose source of wealth files were good enough five years ago are finding that good enough is no longer good enough.
The work to fix it is patient, structural, and unglamorous. It is the kind of work that takes a year and produces no immediate revenue. It is also the kind of work that determines whether a firm comes out of its next supervisory contact with its reputation intact, or with a public Final Notice it spends the next decade trying to live down.
Verigrade structures source of wealth corroboration as a documented evidential chain, not a tick box. Built for FCA-regulated firms that need their files to survive sample testing, Skilled Person review, and supervisory contact.