Source of Funds and Source of Wealth Checks in iGaming

What is the difference between source of funds and source of wealth?

When do operators have to check source of funds?

Most regimes require a risk-based approach rather than one number, then expect operators to follow their own triggers. Some add explicit thresholds.

What triggers should an operator use?

See EDD triggers for how to wire triggers to cases.

What evidence counts?

• Recent payslips matched to bank statements showing salary arriving
• Bank statements showing savings built over time
• Completion statements for a property sale, or sale documents for a vehicle or business
• Solicitor or executor letters confirming an inheritance
• Company accounts or tax returns for business owners
• Investment or pension statements showing a withdrawal
• For crypto-derived money: exchange statements tracing purchase with identified fiat

How should operators ask players for source of funds?

1. Ask earlyTrigger the request as deposits build, not when a withdrawal is pending.
2. Be specificSay which documents and why; accept reasonable alternatives.
3. Give a deadline and next stepExplain what happens if evidence is not provided, such as deposit restrictions.
4. Do not tip offIf a suspicion may be reported, staff must not disclose it.
5. Record the decisionWhat was asked, received and decided, with reasons.

Support teams carry many of these conversations. See how AI support reduces KYC drop-off and the igaming.cx guide on cutting KYC drop-off without weakening compliance. Cevro’s how to automate KYC for online casinos covers automating document conversations.

Who should make source of funds decisions?

The Grosvenor case showed what happens when local managers have discretion over whether evidence is scrutinised ^[2].

How should evidence be assessed?

1. Match the story to the numbersDoes the evidence explain the amounts and timing of deposits?
2. Check documents are genuine and currentLook for alterations and dates.
3. Trace one step backSavings: where did the savings come from? Crypto: where was it bought?
4. Consider affordability separatelyLegitimate funds can still be unaffordable.
5. Record the conclusionAccepted, partially accepted with limits, or not accepted, with reasons.

What should support say when asking for source of funds?

A clear request reduces friction and complaints. For example: “To meet our legal obligations, we need to understand where the money you deposit comes from. Please upload your last three payslips and a bank statement showing your salary being paid in, or another document listed here. We will review it within two working days and let you know the outcome.” Do not suggest the player is suspected of anything, and do not discuss reporting.

What evidence fits each funding source?

Worked example: a review that ends in restriction

1. Week 1
   A player’s deposits rise quickly to well above their usual pattern. An EDD trigger fires and the player is asked for source of funds.
2. Week 1, day 3
   The player uploads a bank statement showing a large transfer in from an unknown third party.
3. Week 2
   The analyst asks for an explanation; the player says it is a loan from a friend.
4. Week 2, day 4
   Evidence does not show the friend’s source of funds; gambling with borrowed money is also a harm indicator. The case is escalated to the MLRO and safer gambling team.
5. Week 3
   Deposits are restricted, the player is contacted by the safer gambling team, and the MLRO decides whether to report.

The outcome balances AML and safer gambling duties. The player is told about the restriction in plain terms but not about any report.

How does a source of funds case run, step by step?

1. TriggerA deposit threshold, velocity pattern, profile risk or analyst referral fires.
2. Open a caseThe system creates a case with an owner and a deadline. NorthStar’s penalty followed a trigger that fired with no case behind it ^[3].
3. Apply interim controlsDepending on policy and risk, deposits may be limited while the case is open.
4. Request evidenceA clear request explains what is needed and why, with examples of acceptable documents.
5. AssessA trained analyst checks that the evidence explains the amounts and timing, and does not assume recycled winnings without proof ^[1].
6. Decide and recordAccept, accept with limits, or reject; escalate to the MLRO where suspicion remains.
7. Monitor and refreshThe evidence has a shelf life. Spending changes or time passing trigger a refresh.

Which regulators set source of funds expectations?

What does a good source of funds programme look like?

Worked example 3: a self-employed player

1. Day 0
   A self-employed player’s deposits cross the operator’s EDD trigger.
2. Day 0
   The request asks for the latest tax return or accounts and three months of business bank statements.
3. Day 2
   The player uploads a tax return showing profit well above their gambling spend, plus statements showing drawings to a personal account.
4. Day 3
   The analyst accepts the evidence, notes the review date, and sets a refresh in twelve months or on a further spending increase.

What have regulators penalised?

Worked example: a source of funds review done right

What mistakes do operators commonly make?

Checklist

• Triggers cover cumulative, velocity, profile and payment risk.
• Every trigger creates a case with an owner and deadline.
• Player-facing requests explain what and why.
• Evidence standard documented, including crypto.
• Decisions recorded with reasons.
• Tipping-off controls in scripts.
• Overdue cases restrict deposits by default.
• Decision roles documented.
• Evidence assessment steps followed.
• Standard request wording with examples.
• Evidence table by funding source shared with analysts.

Frequently asked questions

Sources

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