21/08/2026
Overseas funds can add another layer of complexity to Source of Funds checks.
Legal Compliance Manager Giorgio Dimaria's key message is that firms should go beyond simply obtaining bank statements. The important part is understanding where the money came from, tracing it back to its origin where necessary, and assessing whether the explanation and supporting evidence make sense.
Jurisdictional risk also matters. Funds connected to FATF Black or Grey List countries, or jurisdictions with higher corruption risk or weaker AML controls, may require additional scrutiny and enhanced due diligence.
Where several risk factors are present, the matter may need to be treated as high risk and escalated to the MLRO.
And throughout the process, Giorgio’s advice is simple:
“Document your rationale and let the file speak for itself.”
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