Source of wealth vs. source of funds
These are two different questions, and we have two separate policies for them. Understanding the difference matters because they arise in different situations and are answered with different kinds of documentation.
| Source of funds | Source of wealth | |
|---|---|---|
| The question | Where did the money in this specific transaction come from? | How did you accumulate your overall financial position over time? |
| The scope | Transactional — a single payment or pattern of payments | Biographical — your career, business history, investments, and inherited wealth |
| What triggers it | A specific transaction that meets a SAR evaluation trigger under 31 CFR § 1020.320(a)(2) | A relationship-level risk assessment that indicates the overall scale of wealth needs to be understood |
| Typical documentation | Payslips, bank statements, sale proceeds, exchange records | Employment history, business ownership records, investment statements, estate documents |
| Full policy | source-of-funds | This page |
A source-of-wealth request is not a substitute for, or a repetition of, a source-of-funds request. They address different compliance questions. You may receive one without the other, or both in sequence if the circumstances warrant it.
The legal basis
The legal framework for source-of-wealth inquiries operates at two levels in U.S. federal law.
Mandatory: private banking accounts for non-U.S. persons
Section 312 of the USA PATRIOT Act (31 U.S.C. § 5318(i)) and its implementing regulation at 31 CFR § 1010.620 require a specific due diligence program for private banking accounts. A private banking account is defined as an account, or combination of accounts, that meets all three of the following criteria:
- it requires a minimum aggregate deposit of funds or other assets of not less than $1,000,000;
- it is established on behalf of, or for the benefit of, one or more non-U.S. persons who are direct or beneficial owners; and
- it is assigned to, or administered or managed by, in whole or in part, an officer, employee, or agent of the bank acting as a liaison between the bank and the owner.
For accounts meeting that definition, the bank must ascertain the source of funds deposited and — where a senior foreign political figure is a nominal or beneficial owner — conduct enhanced scrutiny that includes review of the source of the client’s wealth and estimated net worth, reasonably designed to detect and report transactions that may involve proceeds of foreign corruption.
Risk-based: general AML program requirement
For accounts that do not meet the private banking account definition, there is no universal statutory mandate to verify source of wealth. However, the general AML program requirement at 31 CFR § 1020.201(b)(1)(v) requires banks to maintain procedures for understanding the nature and purpose of customer relationships and for ongoing monitoring sufficient to detect suspicious activity. The FFIEC Bank Secrecy Act / Anti-Money Laundering Examination Manual explicitly identifies source of wealth and estimated net worth as factors that may be considered as part of a risk-based due diligence program, particularly when account activity or balances are inconsistent with the apparent economic profile of the relationship.
In plain terms: when the scale of activity on an account cannot be explained by the identity and account type information we collected at opening, and when a source-of-funds inquiry on specific transactions does not resolve the picture, the law’s requirement to understand the customer relationship supports asking about the origin of overall wealth. This is not an extra-legal obligation we have invented — it is the application of risk-based due diligence to the relationship as a whole rather than to individual transactions.
When we ask
A source-of-wealth request arises in one of three situations.
Situation 1: Account activity inconsistent with economic profile
Your account profile — built from your identity verification data and observed transaction history as described in the Source of Funds disclosure — is the baseline against which we evaluate each transaction. If the overall scale or pattern of activity on your account significantly exceeds what the baseline would predict, and if individual source-of-funds inquiries on specific transactions do not resolve the gap, we may ask about source of wealth to understand how you came to hold this level of financial resources. This is a relationship-level question, not a transaction-level one.
Situation 2: Relationship complexity
Some account relationships involve multiple connected accounts, layered ownership structures, or large aggregate balances across the Network. Where the complexity of the overall relationship makes it difficult to evaluate whether activity is consistent with a plausible economic profile from transaction data alone, a source-of-wealth inquiry gives us the broader picture we need to fulfil our ongoing monitoring obligation.
Situation 3: Accounts meeting the private banking definition
Where an account or combination of accounts meets the definition of a private banking account under 31 CFR § 1010.620 — a minimum aggregate balance of $1,000,000 or more, held for the benefit of a non-U.S. person, managed by a designated relationship contact — source-of-wealth review is part of the mandatory due diligence program for that account. In these cases the request is made at account opening or at the point when the account reaches the threshold, and is reviewed periodically thereafter.
In all three situations, you will receive an in-app notification with a specific explanation of what we need and why. We do not ask about source of wealth as a matter of routine, and we do not ask without being able to explain the basis for the request.
What we need from you
Source-of-wealth documentation describes how you accumulated your financial position over time. The right documentation depends on the nature of your wealth. You will not be asked to provide everything on this list — the in-app request will specify which category applies to your situation.
Employment or professional income over time
Where wealth has accumulated through salary, bonuses, or professional fees over a career:
- A letter from your current or most recent employer confirming your role, tenure, and approximate compensation, on company letterhead; or
- Recent tax returns or assessment notices showing income over multiple years; or
- Bank or brokerage statements showing accumulated savings consistent with your career earnings.
Business ownership or sale
Where wealth derives from founding, owning, or selling a business:
- Business registration or incorporation documents establishing your ownership interest;
- Most recent audited or reviewed financial statements of the business; or
- Sale agreement, completion statement, or solicitor confirmation for a business sale, showing the sale price and your net proceeds.
Investment returns
Where wealth derives from investment portfolios, real estate, or financial instruments:
- Brokerage, fund, or custody statements showing the portfolio value and composition over time;
- Real estate appraisals or sale completion statements; or
- Digital asset exchange or custody statements showing historical holdings and disposals, where digital assets form a material part of the picture.
Inheritance or gift
Where wealth derives from inheritance or a significant gift:
- Probate or estate administration documents showing your entitlement and the approximate value of the estate; or
- A signed letter from the donor or the donor’s legal representative confirming the gift amount, together with evidence of the donor’s own source of wealth for the amount gifted.
Combination of sources
Most people accumulate wealth from more than one source over time. If your wealth comes from a combination of employment, investment, and business activity, you do not need to document every component exhaustively — you need to provide enough documentation to make the overall picture plausible and verifiable. If you are unsure which elements to focus on, tap “My situation is different” in the in-app request and a compliance agent will work with you to identify the most relevant documentation.
How to respond
When we need source-of-wealth information, you will receive an in-app notification identifying which of the three situations above applies, what category of documentation is relevant, and the deadline for responding. The standard response deadline is 21 days. If you need more time, tap “Request an extension” — extensions of up to 14 days are generally granted without requiring a reason.
If the documentation category does not match your situation — for example, if your wealth came primarily from a source not listed above, or if the documents you have are in a language other than English — tap “My situation is different”. This routes you to a compliance agent who can discuss your circumstances and identify what will work. We are trying to understand the economic reality of your situation, not collect a specific form.
If you do not respond by the deadline and have not requested an extension, we may place a temporary hold on outgoing transactions while the evaluation remains open. We will tell you this in the in-app request. The hold is lifted immediately once the evaluation is resolved.
What happens next
Once you submit documentation, a compliance analyst reviews it. In most cases you will receive a decision within three business days. If we have a follow-up question, we will contact you through in-app messaging — we will not ask for additional documentation unless the initial submission does not adequately address the question we asked.
If the review is satisfactory:
- Any temporary hold on outgoing transactions is lifted immediately;
- Your account continues under normal operation; and
- The source-of-wealth information is stored in your compliance file. For accounts that are not subject to mandatory periodic review, you will not be asked again unless your account profile changes materially.
If we are unable to verify the source of wealth to a sufficient standard after reasonable engagement, we will notify you and explain our next steps. These may include a request for additional documentation, a limitation on specific account features, or — where the matter cannot be resolved — closure of the account with return of your funds in accordance with the Terms of Service.
For accounts subject to mandatory periodic review under the private banking framework, source-of-wealth information is reviewed at intervals defined in our written AML program. We will contact you in advance of each review cycle.
Common questions
A source-of-funds request asks about a specific transaction — where did a particular deposit or transfer come from. A source-of-wealth request asks a broader biographical question — how did you accumulate your overall financial position. They arise for different reasons and are answered with different types of documentation. Responding to one does not satisfy the other, and receiving one does not mean the other is coming.
It depends on the account. For accounts meeting the private banking account definition under 31 CFR § 1010.620 — a minimum aggregate balance of $1 million or more, held for a non-U.S. person, with a dedicated relationship contact — source-of-wealth review is a mandatory element of the due diligence program under Section 312 of the USA PATRIOT Act. For other accounts, it arises from the risk-based AML program obligation at 31 CFR § 1020.201. The legal basis section of this page explains the distinction in detail.
No. You need to provide enough documentation to make the overall picture plausible and verifiable — not an exhaustive account of every component. In practice, most situations are resolved by documenting the two or three largest sources of wealth. If your situation is complex, tap “My situation is different” in the in-app request and a compliance agent will help you identify what is most relevant.
We accept documents in languages other than English. For documents in languages our compliance team does not read, we may ask for a certified translation of the key sections. Tap “My situation is different” to discuss this before submitting, so we can tell you what level of translation we need for your specific documents.
We share your documents only as required or permitted by law. This includes responding to valid legal process such as court orders or regulatory subpoenas, filing required regulatory reports, and — where we participate — voluntary information sharing with other financial institutions under Section 314(b) of the USA PATRIOT Act for AML purposes. We do not sell your documents or share them for any commercial purpose. The full details are in our Privacy Notice.
Records related to customer due diligence are subject to the same retention requirements as other BSA compliance records — five years after the account is closed, in accordance with 31 CFR § 1020.220 and our written AML program. After the retention period, records are deleted in accordance with our data-retention schedule. While your account is open, you can view the documents you have uploaded in the Account → Compliance section of the ITAM app.
Contact us
If you have questions about a source-of-wealth request or about the process described on this page, please reach us through the in-app messaging feature (Account → Help → Compliance question) or by email:
PayServices Bank — Compliance
950 W Bannock Street, Suite 1100
Boise, Idaho 83702-6140
United States
info@payservices.com
Related policies: Source of Funds · Customer Identification Program · Beneficial Ownership Disclosure · Privacy Notice
Source of wealth vs. source of funds
These are two different questions, and we have two separate policies for them. Understanding the difference matters because they arise in different situations and are answered with different kinds of documentation.
| Source of funds | Source of wealth | |
|---|---|---|
| The question | Where did the money in this specific transaction come from? | How did you accumulate your overall financial position over time? |
| The scope | Transactional — a single payment or pattern of payments | Biographical — your career, business history, investments, and inherited wealth |
| What triggers it | A specific transaction that meets a SAR evaluation trigger under 31 CFR § 1020.320(a)(2) | A relationship-level risk assessment that indicates the overall scale of wealth needs to be understood |
| Typical documentation | Payslips, bank statements, sale proceeds, exchange records | Employment history, business ownership records, investment statements, estate documents |
| Full policy | source-of-funds | This page |
A source-of-wealth request is not a substitute for, or a repetition of, a source-of-funds request. They address different compliance questions. You may receive one without the other, or both in sequence if the circumstances warrant it.
The legal basis
The legal framework for source-of-wealth inquiries operates at two levels in U.S. federal law.
Mandatory: private banking accounts for non-U.S. persons
Section 312 of the USA PATRIOT Act (31 U.S.C. § 5318(i)) and its implementing regulation at 31 CFR § 1010.620 require a specific due diligence program for private banking accounts. A private banking account is defined as an account, or combination of accounts, that meets all three of the following criteria:
- it requires a minimum aggregate deposit of funds or other assets of not less than $1,000,000;
- it is established on behalf of, or for the benefit of, one or more non-U.S. persons who are direct or beneficial owners; and
- it is assigned to, or administered or managed by, in whole or in part, an officer, employee, or agent of the bank acting as a liaison between the bank and the owner.
For accounts meeting that definition, the bank must ascertain the source of funds deposited and — where a senior foreign political figure is a nominal or beneficial owner — conduct enhanced scrutiny that includes review of the source of the client’s wealth and estimated net worth, reasonably designed to detect and report transactions that may involve proceeds of foreign corruption.
Risk-based: general AML program requirement
For accounts that do not meet the private banking account definition, there is no universal statutory mandate to verify source of wealth. However, the general AML program requirement at 31 CFR § 1020.201(b)(1)(v) requires banks to maintain procedures for understanding the nature and purpose of customer relationships and for ongoing monitoring sufficient to detect suspicious activity. The FFIEC Bank Secrecy Act / Anti-Money Laundering Examination Manual explicitly identifies source of wealth and estimated net worth as factors that may be considered as part of a risk-based due diligence program, particularly when account activity or balances are inconsistent with the apparent economic profile of the relationship.
In plain terms: when the scale of activity on an account cannot be explained by the identity and account type information we collected at opening, and when a source-of-funds inquiry on specific transactions does not resolve the picture, the law’s requirement to understand the customer relationship supports asking about the origin of overall wealth. This is not an extra-legal obligation we have invented — it is the application of risk-based due diligence to the relationship as a whole rather than to individual transactions.
When we ask
A source-of-wealth request arises in one of three situations.
Situation 1: Account activity inconsistent with economic profile
Your account profile — built from your identity verification data and observed transaction history as described in the Source of Funds disclosure — is the baseline against which we evaluate each transaction. If the overall scale or pattern of activity on your account significantly exceeds what the baseline would predict, and if individual source-of-funds inquiries on specific transactions do not resolve the gap, we may ask about source of wealth to understand how you came to hold this level of financial resources. This is a relationship-level question, not a transaction-level one.
Situation 2: Relationship complexity
Some account relationships involve multiple connected accounts, layered ownership structures, or large aggregate balances across the Network. Where the complexity of the overall relationship makes it difficult to evaluate whether activity is consistent with a plausible economic profile from transaction data alone, a source-of-wealth inquiry gives us the broader picture we need to fulfil our ongoing monitoring obligation.
Situation 3: Accounts meeting the private banking definition
Where an account or combination of accounts meets the definition of a private banking account under 31 CFR § 1010.620 — a minimum aggregate balance of $1,000,000 or more, held for the benefit of a non-U.S. person, managed by a designated relationship contact — source-of-wealth review is part of the mandatory due diligence program for that account. In these cases the request is made at account opening or at the point when the account reaches the threshold, and is reviewed periodically thereafter.
In all three situations, you will receive an in-app notification with a specific explanation of what we need and why. We do not ask about source of wealth as a matter of routine, and we do not ask without being able to explain the basis for the request.
What we need from you
Source-of-wealth documentation describes how you accumulated your financial position over time. The right documentation depends on the nature of your wealth. You will not be asked to provide everything on this list — the in-app request will specify which category applies to your situation.
Employment or professional income over time
Where wealth has accumulated through salary, bonuses, or professional fees over a career:
- A letter from your current or most recent employer confirming your role, tenure, and approximate compensation, on company letterhead; or
- Recent tax returns or assessment notices showing income over multiple years; or
- Bank or brokerage statements showing accumulated savings consistent with your career earnings.
Business ownership or sale
Where wealth derives from founding, owning, or selling a business:
- Business registration or incorporation documents establishing your ownership interest;
- Most recent audited or reviewed financial statements of the business; or
- Sale agreement, completion statement, or solicitor confirmation for a business sale, showing the sale price and your net proceeds.
Investment returns
Where wealth derives from investment portfolios, real estate, or financial instruments:
- Brokerage, fund, or custody statements showing the portfolio value and composition over time;
- Real estate appraisals or sale completion statements; or
- Digital asset exchange or custody statements showing historical holdings and disposals, where digital assets form a material part of the picture.
Inheritance or gift
Where wealth derives from inheritance or a significant gift:
- Probate or estate administration documents showing your entitlement and the approximate value of the estate; or
- A signed letter from the donor or the donor’s legal representative confirming the gift amount, together with evidence of the donor’s own source of wealth for the amount gifted.
Combination of sources
Most people accumulate wealth from more than one source over time. If your wealth comes from a combination of employment, investment, and business activity, you do not need to document every component exhaustively — you need to provide enough documentation to make the overall picture plausible and verifiable. If you are unsure which elements to focus on, tap “My situation is different” in the in-app request and a compliance agent will work with you to identify the most relevant documentation.
How to respond
When we need source-of-wealth information, you will receive an in-app notification identifying which of the three situations above applies, what category of documentation is relevant, and the deadline for responding. The standard response deadline is 21 days. If you need more time, tap “Request an extension” — extensions of up to 14 days are generally granted without requiring a reason.
If the documentation category does not match your situation — for example, if your wealth came primarily from a source not listed above, or if the documents you have are in a language other than English — tap “My situation is different”. This routes you to a compliance agent who can discuss your circumstances and identify what will work. We are trying to understand the economic reality of your situation, not collect a specific form.
If you do not respond by the deadline and have not requested an extension, we may place a temporary hold on outgoing transactions while the evaluation remains open. We will tell you this in the in-app request. The hold is lifted immediately once the evaluation is resolved.
What happens next
Once you submit documentation, a compliance analyst reviews it. In most cases you will receive a decision within three business days. If we have a follow-up question, we will contact you through in-app messaging — we will not ask for additional documentation unless the initial submission does not adequately address the question we asked.
If the review is satisfactory:
- Any temporary hold on outgoing transactions is lifted immediately;
- Your account continues under normal operation; and
- The source-of-wealth information is stored in your compliance file. For accounts that are not subject to mandatory periodic review, you will not be asked again unless your account profile changes materially.
If we are unable to verify the source of wealth to a sufficient standard after reasonable engagement, we will notify you and explain our next steps. These may include a request for additional documentation, a limitation on specific account features, or — where the matter cannot be resolved — closure of the account with return of your funds in accordance with the Terms of Service.
For accounts subject to mandatory periodic review under the private banking framework, source-of-wealth information is reviewed at intervals defined in our written AML program. We will contact you in advance of each review cycle.
Common questions
A source-of-funds request asks about a specific transaction — where did a particular deposit or transfer come from. A source-of-wealth request asks a broader biographical question — how did you accumulate your overall financial position. They arise for different reasons and are answered with different types of documentation. Responding to one does not satisfy the other, and receiving one does not mean the other is coming.
It depends on the account. For accounts meeting the private banking account definition under 31 CFR § 1010.620 — a minimum aggregate balance of $1 million or more, held for a non-U.S. person, with a dedicated relationship contact — source-of-wealth review is a mandatory element of the due diligence program under Section 312 of the USA PATRIOT Act. For other accounts, it arises from the risk-based AML program obligation at 31 CFR § 1020.201. The legal basis section of this page explains the distinction in detail.
No. You need to provide enough documentation to make the overall picture plausible and verifiable — not an exhaustive account of every component. In practice, most situations are resolved by documenting the two or three largest sources of wealth. If your situation is complex, tap “My situation is different” in the in-app request and a compliance agent will help you identify what is most relevant.
We accept documents in languages other than English. For documents in languages our compliance team does not read, we may ask for a certified translation of the key sections. Tap “My situation is different” to discuss this before submitting, so we can tell you what level of translation we need for your specific documents.
We share your documents only as required or permitted by law. This includes responding to valid legal process such as court orders or regulatory subpoenas, filing required regulatory reports, and — where we participate — voluntary information sharing with other financial institutions under Section 314(b) of the USA PATRIOT Act for AML purposes. We do not sell your documents or share them for any commercial purpose. The full details are in our Privacy Notice.
Records related to customer due diligence are subject to the same retention requirements as other BSA compliance records — five years after the account is closed, in accordance with 31 CFR § 1020.220 and our written AML program. After the retention period, records are deleted in accordance with our data-retention schedule. While your account is open, you can view the documents you have uploaded in the Account → Compliance section of the ITAM app.
Contact us
If you have questions about a source-of-wealth request or about the process described on this page, please reach us through the in-app messaging feature (Account → Help → Compliance question) or by email:
PayServices Bank — Compliance
950 W Bannock Street, Suite 1100
Boise, Idaho 83702-6140
United States
info@payservices.com
Related policies: Source of Funds · Customer Identification Program · Beneficial Ownership Disclosure · Privacy Notice