Source of Funds and Source of Wealth Are Two Different Requests

Where the questions come from

British casino operators, remote ones included, are subject to the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017. The Commission ties that obligation into the licence through licence condition 12.1.1, which requires licensees to comply with the regulations and to have regard to the Commission's own guidance.

The heavier of the two questions has a specific home in the regulations. Regulation 33 sets out when enhanced due diligence must be applied, and provides that the enhanced measures must include obtaining information on the "source of funds and source of wealth of the customer and of the customer's beneficial owner". The triggers listed in regulation 33 are situations, not sums: a high risk of money laundering or terrorist financing, a business relationship involving a country on the Financial Action Task Force's list of high-risk jurisdictions subject to a call for action, a politically exposed person, documents that appear false or stolen, unusually complex or large transactions, and unusual transaction patterns without an apparent economic or legal purpose.

The two questions, side by side

Source of funds is narrow and transactional. Where did this money come from — the money that was deposited, or the money that built the balance now being withdrawn? It is answered by evidence that connects a specific sum to a specific origin.

Source of wealth is broad and biographical. How was the customer's overall wealth accumulated? It is answered by evidence about an accumulation over time rather than a transaction: employment history, the sale of a property or a business, an inheritance, a realised investment.

The practical test of which one has been asked is the shape of the question, not its politeness. A request that names a deposit, a date or an amount is a source-of-funds question. A request that asks about income, occupation or how the money was built is a source-of-wealth question, and it signals that enhanced due diligence has been engaged rather than ordinary checks.

Why there is no universal document list

Because the regulations are risk-based rather than threshold-based. Regulation 33 is written around circumstances in which enhanced measures must be applied, and the Commission's guidance for casino operators approaches the two concepts the same way: the licensee has to decide what evidence is proportionate to the risk it has identified in that relationship.

This has two consequences that cause most of the friction.

• There is no figure at which the request automatically arrives, and no figure below which it cannot. Published "limits" above which a casino "must" ask for documents are not in the regulations; what is in them is a set of risk situations.
• Two licensees can legitimately ask for different evidence in materially similar cases, because each has made its own risk assessment and each is answerable for it.

What happens if the evidence is not provided

The duty does not evaporate when a customer declines. Where a licensee cannot satisfy itself about source of funds or source of wealth, it is required to act on that, and the available actions include restricting or ending the business relationship. The relevant point for a player is that this is not the operator exercising discretion over a payout: the obligation runs the other way, and an operator that paid out while unsatisfied would be the one in difficulty.

That also explains why the request can arrive at withdrawal rather than at deposit. A pattern becomes visible across a relationship, and the regulations contemplate monitoring an existing relationship rather than a single gate at the start of it.