Source of Funds Checklist
The Legal Sector Affinity Group Guidance 2023:
Source of Funds refers to the funds that are being used to fund the specific transaction in hand – i.e., the origin of the funds used for the transactions or activities that occur within the business relationship or occasional transaction. The question you are seeking to answer should not simply be, “where did the money for the transaction come from,” but also “how and from where did the client get the money for this transaction or business relationship.” It is not enough to know the money came from a UK bank account.
Exclusions to note
Sample template bundles do not include a template to show the structure of the residential conveyancing department at a firm. The data protection policy template covers the requirements of CQS, however it is the responsibility of the firm to ensure it is compliant with the requirements of the General Data Protection Regulation.
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