An importer you have banked for years starts paying a new overseas supplier far above market prices for ordinary goods. The goods are shipped and invoiced normally.
Source of Wealth: What a Bank Asks and Why
The transfer has a paper trail. The fortune needs a history.
BY MICHAEL SHANG · SIXTEEN YEARS IN COMMERCIAL BANKING · UPDATED
// THE SHORT ANSWER
Source of wealth is the bank's account of how a customer came to own what they own: the career, business, property sales or inheritance that built their net worth. It matters when the bank must apply enhanced due diligence, because a single payment can be perfectly documented and still belong to a fortune that makes no sense. The bank is not auditing every asset. It wants a history that explains the size of the wealth, evidenced in proportion to the risk, and it compares that history with what the customer then does on the account.
BASIS Practitioner judgment from sixteen years in commercial banking, set out in How Bankers Think (Highbank Press, 2026). Every borrower on this site is a composite constructed for teaching, not a client. The market is mid-market commercial lending as practised in New Zealand and Australia; where a convention differs elsewhere, the page says so.
// PRACTISE THE ROUND
Five questions commercial banking panels genuinely ask, with the senior interviewer's read on every answer — a quiz that tests judgment, not recall.
// 01 — WHY A BANK ASKS HOW SOMEONE GOT RICH
The last stage of laundering is to make criminal money look like ordinary wealth: a property, a portfolio, a business bought with funds from a respectable account. A bank checking only the transaction would see a clean transfer and a signed agreement. Source of wealth asks the earlier question. If the customer's history explains the size of what they hold, the transaction fits; if not, tidy paperwork on one payment is no comfort.
In commercial banking the question comes up more often than the private-banking picture suggests. Owners and guarantors of a business, buyers putting equity into an acquisition and new customers arriving with money made elsewhere all bring wealth the bank has to understand before it lends against it or holds it.
// 02 — WHEN THE RULES REQUIRE IT
The requirement travels with enhanced due diligence, and each market draws the lines differently. In the UK, the Money Laundering Regulations 2017 require adequate measures to establish both source of wealth and source of funds for a politically exposed person (PEP), their family members and known close associates, and information on both for relationships involving a country on the FATF's call-for-action list. For other higher-risk customers the measures are the bank's risk-based choice. Since 2024 a UK PEP starts from a lower risk than a foreign one, and the FCA's 2025 guidance expects lighter steps in lower-risk cases, such as using information the bank already holds.
In Australia, the AML/CTF Rules 2025, in force from 31 March 2026, make source of wealth and source of funds matters the bank must establish for every foreign PEP, and for domestic and international-organisation PEPs where the customer's risk is high. They also apply, so far as relevant to the risk, where enhanced due diligence is triggered by high risk, by a suspicious matter report on a customer the bank keeps, or by a FATF call-for-action jurisdiction. Customers identified under the old rules keep their initial checks; for them the question comes through ongoing due diligence.
In New Zealand, enhanced due diligence covers trusts, customers the bank assesses as higher risk, unusually large or complex transactions, non-residents from countries with weak controls and PEPs, among others. The Department of Internal Affairs, sole supervisor since July 2026, says most of these cases need information on source of wealth, source of funds or both, verified by reasonable steps according to the risk, and the bank's programme must say when it examines which. A New Zealand PEP is someone who has held a prominent overseas function in the past twelve months, with their family and close associates, so those rules reach foreign officials, not domestic ones.
// 03 — THE EXAMPLE
A buyer, constructed for this page like every figure in it, is acquiring a freight-forwarding business for US$9.0m through a new company, and the bank will lend US$5.0m. The buyer moved to the country three years ago and most of the equity is arriving from an account overseas, so the bank rates the relationship higher risk and applies enhanced due diligence. Both questions are asked.
Source of funds is the narrow check: statements for both accounts, showing how the balances built up and the route of the transfer. Source of wealth is the wide one: how the buyer came to hold US$4.0m in cash and a house.
Evidence follows each line: the 2021 sale agreement and settlement statement for the buyer's share, the apartment's settlement statement, tax returns for the salary years and fund statements for the returns. The bank does not trace every dollar; it needs the size and shape of the wealth to fit the history. One item stops the file. A US$0.3m payment into the overseas account last year came from a company the buyer had not mentioned. Asked, the buyer produces the sale agreement's deferred-payment clause: the payer is the firm that bought the business, settling its last instalment. The anomaly was part of the history already told.
// 04 — WHAT A LENDER READS BESIDE IT
Source of funds is tied to a movement of money: where this deposit, this equity or this repayment came from, checked against documents specific to it. Source of wealth is the customer's whole history, checked for plausibility rather than completeness. Each can pass while the other fails. A transfer can be documented to the cent while the fortune behind it has no history; a long, well-evidenced career can sit behind a payment that arrives from a stranger's account.
The credit file reads the same papers for a different question. A guarantor's statement of position asks whether the wealth is there and whether the bank could reach it; source of wealth asks how it got there. Once the purchase settles, the buyer's cash is in the business, and a personal guarantee would rest on US$1.1m of home equity. One set of documents serves both reviews, and neither answer stands in for the other.
DEFINED IN ONE PARAGRAPH → · THE EQUITY IN AN ACQUISITION → · BENEFICIAL OWNERSHIP →
// 05 — WHERE IT DECIDES A FILE
Source of wealth decides timing more often than it decides the answer. Enhanced due diligence generally has to be done before the relationship begins, so a file that needs overseas documents, translations or a former employer's confirmation can delay drawdown, and an acquisition with a fixed settlement date puts that work on its critical path. Raising it at the term sheet gives the customer time.
When the answer does not come, the rules decide. In New Zealand, a bank that cannot complete required enhanced due diligence must not establish the relationship, must end an existing one (as soon as practicable, in the supervisor's view) and must consider a suspicious activity report. In Australia, a bank must not begin a service until it has established the initial due diligence matters, which for a foreign PEP include source of wealth and source of funds. The UK regulations bar opening or continuing a relationship where customer due diligence cannot be applied and require the bank to consider a report; the enhanced measures are owed on top of that duty. A gap that stays unexplained is not a credit point to be priced. It is a reason the file cannot proceed.
THE EXAM HALL · AML AND FINANCIAL CRIME → · THE EXAM HALL · PRIVATE BANKER →
// SOURCES
The documents the statements on this page rest on. Each was opened and checked when cited.
- The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (UK), regulation 35 — politically exposed persons — Requires adequate measures to establish source of wealth and source of funds for PEPs, family members and known close associates, with domestic PEPs starting from a lower risk under 35(3A) — section 02.
- Anti-Money Laundering and Counter-Terrorism Financing Rules 2025 (Cth), rules 6-21, 6-23 and 6-42 (registered 29 August 2025, commencing 31 March 2026) — Specifies source of wealth and source of funds for foreign PEPs, for domestic and international-organisation PEPs where risk is high, and where enhanced due diligence is triggered under section 32(a), (b) or (d) of the Act so far as relevant to the risk, and treats customers identified before 31 March 2026 as having completed initial due diligence — sections 02 and 05.
- Department of Internal Affairs (NZ), Guidance: Enhanced Customer Due Diligence, version 2.0 (July 2026), paragraphs 19–20, 35–36, 49–54, 89–90, 130–131 and 153–158 — Distinguishes source of wealth from source of funds, leaves the choice to the bank's programme, lists verifying documents, bars or ends a relationship where enhanced due diligence cannot be completed and requires a report to be considered, and defines a PEP by an overseas function including family and close associates — sections 02, 03 and 05.
// QUESTIONS PEOPLE ASK
- Why does my bank want to know my source of wealth?
- Because anti-money-laundering rules ask it to understand customers and situations that carry more risk, and laundered money distorts the size of someone's wealth. A request does not mean the bank suspects you. It is usually triggered by the kind of relationship, such as a large deposit, money from overseas, a trust or a public role, and the bank must record the answer. A short, documented account of how the money was made, given early, tends to settle it.
- What documents prove source of wealth?
- Documents from someone other than the customer that match each part of the story: a sale agreement and settlement statement for a business or property sold, probate or letters of administration for an inheritance, payslips or tax returns for employment income, investment statements for returns, accounts for a business owned. New Zealand's supervisor lists documents of this kind. The higher the risk, the more a bank expects originals or certified copies, or confirms details with the source directly.
- Do banks check source of wealth for every customer?
- No. It belongs to enhanced due diligence, which applies to higher-risk customers and situations, not to every account; standard due diligence asks who the customer is and what the relationship is for. Even within enhanced due diligence the depth varies. UK guidance expects lighter steps for a lower-risk domestic politically exposed person than for a foreign one, and in New Zealand the bank's own programme sets out when it examines wealth, funds or both.
- Does source of wealth apply to a company?
- Yes, though the question moves towards the people behind it. For a company, the bank looks at how the business made its money, through its accounts and trading history, and at the wealth of the beneficial owners who funded or control it. The UK regulations ask for information on the beneficial owner's sources as well as the customer's in some high-risk cases, and for a trust, New Zealand's guidance points to the settlor and how the settlor's wealth was made.
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