Source of Funds has, until recently, largely been viewed through the lens of property transactions.

For many firms, it has been associated with a conveyancer requesting bank statements before exchange, a mortgage lender asking for proof of a deposit, or a cash buyer being asked to evidence where funds have originated. While these scenarios remain important, they represent only part of the picture.

The reality is that Source of Funds sits at the heart of regulated activity across multiple sectors. Wealth managers accepting significant client contributions, investment platforms onboarding new customers, lenders verifying a borrower's capital contribution, and professional services firms handling large transactions all face the same fundamental question: can they evidence the origin of the funds involved in a transaction?

As regulatory expectations continue to increase, firms are being asked not only to perform Source of Funds checks, but to do so in a way that is consistent, auditable and capable of standing up to scrutiny.

Today, we are formally launching an expanded version of the SmartSearch Source of Funds product, built specifically to support the wider range of regulated transactions that firms are increasingly being asked to evidence and document.

Alongside the existing property-focused capabilities, the product now supports investment platforms, wealth managers, lenders, financial services firms and other regulated businesses where a specific transaction requires evidence of the origin of funds.

The core objective remains the same. Fragmented evidence collection, repeated customer contact and manual review are replaced with a single, structured, digital journey. What is new is the breadth of regulated transactions the product can support, alongside the depth of configuration available to firms operating across different sectors.

What Has Changed?

The updated SmartSearch Source of Funds product introduces two configurable journeys designed to help firms evidence the origin and availability of funds in a structured and consistent way.

The Standard Journey

The Standard journey is designed to verify the origin and availability of funds associated with a specific regulated transaction.

It combines a dynamic questionnaire, Open Banking connectivity and secure document upload into a single customer journey.

Customers begin by declaring the origin of their funds. The questionnaire then adapts based on their responses, requesting information relevant to the declared source. Depending on circumstances, this may include salary savings, investment returns, inheritance funds, property sale proceeds or other legitimate sources.

Customers can securely connect relevant bank accounts through Open Banking, providing transactional visibility and reducing the need for manual document handling. Additional supporting evidence such as payslips, investment statements or documentation relating to an asset sale can also be uploaded directly within the journey.

Once complete, the customer reviews the report before sharing it with the firm.

The Standard journey is designed to capture key information consistently, including:

• The origin of funds
• How funds have accumulated
• The amount available
• Supporting documentation
• Third-party gifts or contributions where applicable
  
  

The result is a structured, audit-ready report that provides firms with a clear evidential record.

The Refresh Journey

The Refresh journey is designed as a lightweight follow-up verification.

In many cases, firms need to confirm that funds remain available after an initial Source of Funds assessment has already been completed. This can happen before a transaction completes, before funds are released or before a lending facility reaches drawdown.

Rather than asking customers to repeat the entire process, the Refresh journey focuses specifically on confirming fund availability through a shorter Open Banking review.

This provides firms with a practical way to verify that circumstances have not materially changed since the original assessment.

Specialist Property Journeys

For property firms, specialist residential and gifted deposit journeys remain available, reflecting the specific requirements of residential conveyancing and mortgage-related transactions.

These tailored workflows continue to support the property sector while the new Standard and Refresh journeys enable broader application across other regulated activities.

Designed Around the Firm

No two firms approach Source of Funds in exactly the same way.

Different sectors face different risk profiles, transaction types and regulatory expectations. The updated SmartSearch product has therefore been designed to provide flexibility without sacrificing consistency.

Each firm can configure the journeys available to its users, ensuring they only see the options relevant to their regulated activities.

Banking data review periods can also be configured according to requirements:

• Standard journeys support reviews of 6, 12 or 24 months
• Refresh journeys support reviews of 3 or 4 months

This allows firms to align evidence collection with the nature of the transaction and the timeframe over which funds have accumulated.

The customer-facing experience can also be branded, creating a journey that feels like an extension of the firm's own service rather than a disconnected third-party process.

Powered by Armalytix, Endorsed by Legal Eye

The Open Banking element of the solution is powered by Armalytix, an FCA-authorised Account Information Service Provider that is already used in a significant proportion of UK residential property transactions.

Through Open Banking, firms gain access to verified transactional information directly from customer accounts, reducing reliance on manually provided statements and helping create a clearer audit trail.

The questionnaire content used within the Standard journey has also been reviewed and endorsed by Legal Eye.

This provides additional confidence that the information being collected is aligned with the practical requirements firms face when meeting their AML compliance obligations.

Together, these partnerships bring together regulated infrastructure and specialist compliance expertise, creating a Source of Funds solution designed to support firms operating in increasingly demanding regulatory environments.

Why This Matters Now

The timing of this launch is significant.

Across regulated sectors, expectations around customer due diligence, transaction monitoring and evidencing financial activity continue to rise.

The Solicitors Regulation Authority's updated Sectoral Risk Assessment, published in 2026, identified sources of funds and wealth as a key control across multiple higher-risk areas.

The Economic Crime and Corporate Transparency Act continues to reshape how firms approach economic crime prevention, while the Failure to Prevent Fraud offence will introduce a new level of corporate accountability from 2027.

At the same time, further changes to the Money Laundering Regulations are expected, placing additional focus on evidence, transparency and defensible decision-making.

The direction of travel is clear.

Firms are increasingly expected to demonstrate not only that checks have been performed, but that they were performed consistently, proportionately and with an appropriate evidential record.

Compliance and Customer Experience Can No Longer Be Separated

Regulatory pressure is only one side of the equation.

Customer expectations are changing too.

Recent research conducted by Credas, part of the SmartSearch Group, found that 39% of homebuyers identify proof of funds as the most frustrating part of the compliance journey.

Customers increasingly expect digital-first experiences, faster processes and fewer requests for duplicate information.

At the same time, compliance failures can have a significant impact on trust. Consumers are becoming more aware of financial crime risks and are placing greater emphasis on doing business with organisations that take compliance seriously.

This creates a challenge for firms.

They must strengthen compliance controls while simultaneously improving customer experience.

The traditional approach of collecting documents through lengthy email chains and manually reviewing evidence is increasingly difficult to justify from either perspective.

Responding to Demand

The growth in Source of Funds activity across the SmartSearch platform reflects these market changes.

Check volumes have increased significantly during 2026 as firms respond to tighter regulatory expectations and growing demand for more structured approaches to evidencing the origin of funds.

What was once viewed as a specialist compliance requirement is becoming a more routine part of regulated transactions across multiple sectors.

As expectations increase, firms need solutions capable of delivering consistency, efficiency and auditability at scale.

Available Today

The expanded SmartSearch Source of Funds product is available now.

Existing SmartSearch customers can speak with their Customer Success Manager about enabling the new journeys and exploring the options available to their firm.

For organisations evaluating their current Source of Funds process, our team can demonstrate how the product fits within existing workflows and regulatory requirements.

For firms operating beyond the traditional property use case, this is Source of Funds redefined.

Structured. Digital. Audit-ready.

Built to support the wider range of regulated transactions that firms are increasingly being asked to evidence and document.