What is Source-of-Funds verification via Open Banking and what counts as evidence?

Source-of-Funds verification via Open Banking pulls a customer's 12-month transaction history through a PSD2-licensed Account Information Service Provider (AISP) under one-time read-only consent. The provider returns a categorised summary (salary / savings / asset-sale / gift / inheritance / dividend / business-income) plus the underlying transactions, which the regulated firm reviews against the declared source. Open-Banking SoF is now the default approach for letting-agent + conveyancer + accountant workflows under MLR-2017 enhanced due diligence triggers because it produces an audit-grade evidence pack in seconds rather than the days a manual bank-statement review takes.

Under MLR-2017 reg 33, SoF is mandatory when an enhanced due diligence trigger fires: politically-exposed person involvement, high-risk-third-country residence, complex or unusually large transaction, no-apparent-economic-purpose transaction, or any transaction the firm's risk assessment flags. The trigger list is non-exhaustive — firms regulated under LSAG-2025 routinely apply SoF to all property transactions over £100,000 as a matter of policy.

Acceptable SoF evidence categories: regular salary (with confirmed employer), accumulated savings (with audit trail back at least 12 months), proceeds of asset sale (with sale documentation), gift (with donor identification + their own SoF), inheritance (with grant of probate), dividend or director's-loan repayment (with Companies House cross-reference), business-income (with management accounts). Refused / unclear SoF is itself a regulator-reportable Suspicious Activity Report trigger to the National Crime Agency.

Source: FCA — Source of Funds Guidance

Last updated 2026-05-09.