The property sector has been the visible face of Source of Funds compliance for years, but the underlying regulatory obligation has always sat much wider. Any regulated firm handling a specific transaction where the origin or availability of money matters is potentially in scope. Investment platforms opening a portfolio for a new client. Wealth managers accepting a significant contribution. Lenders confirming a borrower's own capital before drawdown. Legal firms handling client money on a settlement. Every one of these transactions carries a source of funds obligation, and every one has, until recently, been managed through the same fragmented mix of emails, bank statements and manual review.

The updated SmartSearch Source of Funds product has been designed to change that. Alongside the specialist residential and gifted deposit journeys already supporting the property sector, the product now offers configurable Standard and Refresh journeys built for the wider regulated economy.

Here is how those journeys are being used in practice.

Wealth and investment: verifying the origin of a new client's contribution

When a new client makes an initial investment of any size, or an existing client tops up their portfolio significantly, the wealth manager or investment platform needs to understand and evidence where the money has come from. Salary savings accumulated over years. An inheritance received. Proceeds from the sale of an asset or business. Investment returns from another platform. Each of these has its own evidence trail, and each carries a different risk profile depending on how the money moved.

The Standard journey captures this in a single flow. The customer declares the origin of the funds. The dynamic questionnaire adapts based on that declaration, asking for the right supporting information. Open Banking allows the customer to connect the accounts through which the money moved, giving the wealth manager visibility of transactional history over 6, 12 or 24 months. Any supporting documents (share certificates, investment statements, evidence of sale, funding agreements) are uploaded through the same journey and stored alongside the completed report.

For wealth firms, the immediate value is a structured, audit-ready record of the money's origin. The broader value is a customer onboarding experience that no longer relies on the client emailing bank statements from multiple accounts to multiple team members over multiple weeks.

Lending: verifying a borrower's own contribution or capital

Lenders offering mortgages, personal lending, or business finance are increasingly asked to verify not just the borrower's ability to repay, but the origin of the capital they are bringing to the transaction. A borrower putting down a deposit alongside a mortgage. A business owner contributing personal capital alongside a commercial loan. A restructuring where existing capital is being applied against a new financing arrangement. In each case, the lender needs to understand where the borrower's own money has come from and whether it remains available at the point of drawdown.

The Standard journey handles the initial verification. The Refresh journey handles the follow-up. Where a lender needs to confirm that the borrower's capital is still in place before releasing funds, the Refresh journey provides a fast, three- or four-month balance check without requiring the borrower to complete the full questionnaire again. That combination is designed for exactly the operational reality of lending, where circumstances can change between initial approval and drawdown.

Financial services: enhanced due diligence on specific transactions

For FCA-regulated financial services firms, source of funds is often triggered by a specific transaction rather than a routine onboarding requirement. A significant one-off customer deposit. The funding of a regulated product. Enhanced due diligence on a client presenting elevated risk factors. In each case, the compliance question is the same. Where has this specific money come from, and can we evidence it?

The Standard journey provides that evidence in a consistent, repeatable format. Every case, regardless of trigger or transaction type, produces the same structured report. That consistency matters when compliance teams are reviewing dozens or hundreds of cases per week, and when audit teams are looking back across a portfolio to check that source of funds was handled uniformly.

Legal firms and other regulated businesses: significant client payments and settlements

Beyond property, legal firms handling client money face source of funds obligations across a wide range of transactions. Divorce settlements. Estate distributions. Litigation proceeds. Trust distributions. Each of these can involve significant sums, third-party contributions, and complex fund histories. Manually assembling the underlying evidence is time-consuming, and the resulting audit trail is often fragmented across email chains and case files.

The Standard journey provides a single structured process that captures the customer's declarations, the underlying banking data (where available), and any supporting documents in one place. For firms handling client money at scale, the operational efficiency is significant. The compliance defensibility is even more so.

How to know if this fits your firm

The clearest indicator that Source of Funds should be a structured part of your workflow is that your firm is already asking clients for evidence of where money has come from, and that process currently relies on manual document collection. If your compliance team spends time chasing bank statements, reconciling multiple sources of evidence, or reconstructing a client's fund history from fragmented information, the Standard journey will do that work for them.

The second indicator is that your firm's regulatory environment is tightening. The SRA's updated Sectoral Risk Assessment, the Failure to Prevent Fraud offence coming in 2027, expected Money Laundering Regulations amendments, and the FCA becoming the single AML supervisor for legal firms by 2027 all point the same direction. Firms already investing in structured source of funds processes will find themselves ahead of that curve.

Getting started

For firms considering how the updated SOF product would fit into their workflow, the best next step is a short conversation with our team. We can walk through your current process, understand the transactions where source of funds sits in your risk framework, and show you what a configured journey would look like for your specific use case.