Source of wealth verification with every dollar traced to cited evidence before the BSA/AML Officer signs
Every dollar of a client's wealth traced to cited evidence before the BSA/AML Officer signs.
See one case, screen by screen ↓Source of wealth verification is the enhanced due diligence step where a private bank or wealth manager proves, with evidence, how a high-risk client built their wealth and where the money being deposited comes from (source of funds). Source of Wealth Verification puts seven AI agents on the file: they read the evidence in any language, rebuild the wealth history reconciled to declared net worth, test it, screen news and size any unexplained amount in dollars, while an analyst, a checker and the BSA/AML Officer sign.
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Source of wealth verification is the slowest step in onboarding a high-risk, high-net-worth private banking client. In private banking KYC, before the firm takes the money, an analyst has to show, with evidence, how the client became wealthy and where the deposit comes from. For an international client that evidence is a share purchase agreement in Spanish, a notarial deed, Danish estate papers, tax returns and custodian statements. The analyst reads them by hand, orders translations, re-keys amounts into a spreadsheet, searches registries and news mostly in English, and writes a free-text narrative.
The risk sits in what nobody had time to check. Narratives restate the client's own declaration without corroboration, local-language news goes unread, name matches are cleared without identifiers, and the banker sends the client a vague request for “more documents”, then another. The BSA/AML Officer signs without knowing, in dollars, how much is still unexplained, and regulators keep fining firms whose files did not test the client's story.
Estimated split for one high-risk client with evidence in two or three languages, by hand and with the solution, in business days. Time waiting on the client is not counted.
Seven agents read, rebuild, test, screen and size the gap; an analyst prepares, a checker checks, the BSA/AML Officer approves.
Mateo Arriaga Lund, 54, a Mexican and Danish citizen living in Monterrey, plans to book $24.0M with Quillfield Private Wealth in New York. He is high risk (78): a non-US person with a private banking account over $1M, and his spouse's brother is a sitting state legislator in Nuevo León. His enhanced file, EDD-26-04417, is due October 20. Here is how the agents and three people verify his source of wealth and source of funds in the working solution.
Daniel's day starts with what the agents did overnight: 212 documents read in 11 languages, 64 wealth histories rebuilt or updated, 1,906 news articles screened with 4 to confirm, and 9 document requests drafted, none sent. Five things need him, sorted by deadline, each with one action. Mateo Arriaga Lund is first, due tomorrow.
“Overnight we read 212 new documents in 11 languages across 64 files and prepared every file for you.”
The wealth story draws Mateo's net worth as streams flowing into $38.6M, each as wide as its amount: the 2019 sale of his logistics company ($21.3M), salary and bonuses from 2008 to 2019 ($3.8M), investment growth ($11.8M) and a 2021 inheritance ($4.9M), with $3.2M of tax on the sale leaving the river. $36.2M is explained by 13 documents. $2.4M of the inheritance is hatched as unexplained. Beside it, the agents say what they did, with citations, and ask before they act.
Evidence agent: “The probate record arrived: 14 pages in Danish, Aarhus probate court case BS-1184/2021. Shall I read it and recompute the gap?”
Clicking the business sale opens the source drawer. Clause Tercera of the share purchase agreement sits beside its English reading, with the price, MXN 410,000,000, highlighted on page 7. The amount is converted at 19.25 MXN per USD on March 18, 2019, the day the money arrived, to $21.3M. Four documents back the stream, read at 96–99% confidence, and the corroboration standard is met: agreement, proof of receipt and one independent source.
The agents never treat a translation as the original. The Spanish stays on screen.
The Plausibility agent tested the sale at 5.0× 2018 EBITDA against 4.2–7.8× across 23 Mexican freight and logistics deals (plausible, 91%), the proceeds against the agreed price (99%), and CEO pay of MXN 9.6M against a peer band of MXN 7–12M (88%). The Adverse Media agent read 412 Spanish, 37 Danish and 96 English articles. A Diario Regio story about Transportes Arriaga Hermanos named a different company, with a different tax ID and owners; the agent proposed “not our client” at 94%, and Daniel confirmed it with a reason code.
The Plausibility agent explains its benchmark and source; it never decides.
His mother's estate in Aarhus was divided between two heirs. The lawyer's letter and a bank receipt prove the first distribution of DKK 15.8M; the second, DKK 15.1M or $2.4M, had no evidence. The Gap agent sized it in dollars and drafted one request for the probate certificate and final estate accounts, or the bank statement showing the second distribution. Daniel approved the draft on October 12, Sofia Castellanos sent it on October 13, and the record arrived on October 16.
The Gap agent never contacts a client: the analyst approves, the banker sends.
The next item on Daniel's list is the same kind of request for another client: Hiroshi Kanemoto-Ward has $1.1M of digital-asset gains backed only by wallet screenshots. The Gap agent's draft asks for exchange statements for the sale of 41.2 BTC and the bank transfer of the proceeds, and explains why this document. The route is fixed: drafted by the agent, approved by the analyst, sent by the banker, answered by the client.
“Agents never contact clients. The analyst who approves cannot send; the banker sends through the CRM, and the message is logged.”
Daniel says yes. The Evidence agent reads the Danish probate record: net estate DKK 61.8M, two heirs, second distribution DKK 15.1M on November 9, 2021, matching the custodian inflow two days later. The Wealth History agent marks the inheritance fully corroborated at $4.9M, the Plausibility agent re-runs its test (93%), and the Narrative agent drafts the narrative. Unexplained goes from $2.4M to $0.
“All $38.6M is explained. The gap is closed.”
The source-of-wealth narrative runs seven paragraphs with 22 citations, each a chip to the document and page, and covers source of funds: the initial $24.0M comes from his own account at Øresund Privatbank, Copenhagen. The enhanced due diligence checklist is met, 8 of 8. Amara did not prepare the file, so she may check it; she passes it or returns it with a reason code such as “Sentence without a citation”.
The person who prepares a file can never check or approve it.
Helen sees net worth $38.6M, unexplained $0 and risk 78 with the PEP relative. She approves with conditions under reason DE-01 “Wealth fully corroborated”: review again in 12 months (October 19, 2027) and alert on any inflow over $2M not from the declared custodians. She attests that she has read the narrative and the sources, and types her name as her e-signature.
Only the BSA/AML Officer decides a high-risk client.
Every action by a person or an agent is on the audit trail, each entry chained to the one before. The examiner pack for EDD-26-04417 holds nine sections: the narrative, the wealth history and reconciliation, all 14 documents with their English readings, the plausibility tests, adverse media and political exposure, the document request, the decisions and sign-off, the audit trail, and the policy in force. It exports as a PDF with an index, plus JSON, under a SHA-256 seal.
“One file a regulator or auditor can read without our systems: everything cited, signed and sealed.”
The same enhanced file, seen by five of the people who carry it: what source of wealth checks looked like by hand, and what they look like now.
Seven agents read, rebuild, test, screen and size the gap; an analyst prepares, a checker checks, the BSA/AML Officer approves.
Reads and classifies every document in its original language, puts an English reading beside it, and extracts amounts, dates and parties cited to the page.
Rebuilds the client's wealth as streams in and out, converts each at the FX rate on its date, and reconciles to the declared net worth.
Tests each event against the world: a sale price against the company's revenue and deal multiples, pay against peers, an inheritance against the estate, growth against a benchmark.
Searches news, court and regulatory sources in the language of each source document, and resolves name collisions with identifiers such as tax IDs and owners.
Sizes what is unexplained in dollars and drafts one request for the single document that would close it.
Writes the source-of-wealth and source-of-funds narrative, every sentence cited, and the enhanced due diligence checklist beside it.
Schedules periodic reviews by risk tier, opens a review on a trigger such as a large inflow, prepares delta reviews, keeps the sealed trail and builds examiner packs.
Prepare, check, approve. The agents propose; a named person decides.
Ask a question or give an instruction beside the wealth story. The agent that knows answers, cites the page, and shows you a change before it makes it. Every question is logged on the file.
What is still unexplained in Mateo Arriaga Lund's wealth?
$2.4M (DKK 15.1M): the second distribution from his mother's estate. The lawyer's letter gives two equal heirs and the first DKK 15.8M is evidenced. The probate record arrived Friday and should close it.
Which files are at risk of missing their SLA this week?
23 files are at risk. 9 wait on clients, 6 on a checker, 8 on analysts. The two closest are Mateo Arriaga Lund (due Oct 20) and Chen Weiyuan (Oct 20, with the BSA/AML Officer).
Draft the request for Hiroshi Kanemoto-Ward's missing evidence
Already drafted: REQ-26-1207 asks for exchange statements for the 2024 sale of 41.2 BTC and the bank transfer of about $1.1M. Wallet screenshots alone do not meet the standard. It needs your approval; Arjun Mehta sends it. I never contact clients.
Build the examiner pack for EDD-26-04417
The pack holds the narrative, the wealth history, all 14 sources with English readings, 6 tests, 545 screened articles, the request, the sign-off and the sealed trail. Choose what to include and export.
13 screens from the working solution, on its sample data. Pick one to see it large.
The rules every enhanced file is checked against are settings. An administrator proposes a change, the Head of Financial Crime Compliance approves it, and the agents are re-tested on past decided files before a threshold change goes live.
| Setting | Default | Choose from |
|---|---|---|
| Corroboration standard: sale of a business | Sale agreement + proof of receipt | Plus one independent source: registry, buyer filing or press |
| Corroboration standard: inheritance | Probate record or certified will + proof of receipt | Independent source: court or notary record |
| Gap tolerance | $100K or 0.5% of net worth, whichever is lower | Above it, the Gap agent drafts a request |
| Enhanced file opens at | Risk score 60, or a private banking account over $1M for a non-US person | From the risk model in the client onboarding system |
| Review cycle | High 12 months · medium 24 · low 36 | Plus trigger reviews: inflows, adverse media, PEP changes, jurisdictions |
| Trigger: large inflow | Over $2M, or 20% of declared net worth, not from a declared source | Opens a delta review; freezes nothing |
| Escalation when unexplained | Over 10% of net worth after two requests | Goes to the Head of Financial Crime Compliance |
| Service levels | New client file in 10 business days; BSA/AML Officer decision in 2 | Client request reminder after 5 days, overdue after 10 |
Every figure is labelled: a target the solution is built to, an estimate, a typical published result, or a proven one.
“demo” = seen in the working solution, on its sample data · “target” = the design goal, measured in the live solution · “estimated” = our estimate · “typical” = published figures (MAS composition penalties of S$27.45M on nine financial institutions, July 4, 2025, for inadequate source-of-wealth checks; a wealth-technology vendor's survey of wealth management professionals, published July 2024 — 29% say onboarding an ultra-high-net-worth client takes three months or more). Regulations named for context: 31 CFR 1010.620; FATF Recommendations 10 and 12; Wolfsberg FAQs on Source of Wealth and Source of Funds (2020); UK Money Laundering Regulations 2017; EU AML Regulation 2024/1624. People, firms, clients and companies named on this page are fictional — characters and sample data in the working solution.
Source of wealth verification is the enhanced due diligence step where a private bank or wealth manager proves, with evidence, how a high-risk client built their wealth and where the money being deposited comes from (source of funds). Source of Wealth Verification puts seven AI agents on the file: they read the evidence in any language, rebuild the wealth history reconciled to declared net worth, test it, screen news and size any unexplained amount in dollars, while an analyst, a checker and the BSA/AML Officer sign.
Source of wealth is how the client's whole body of wealth was built: a business sale, an inheritance, salary, investment growth. Source of funds is where the money for this account comes from and how it will be funded, and source of funds verification confirms it. Together they are often called SOW and SOF checks; the solution's narrative covers both, and in the sample file the initial $24.0M comes from the client's own account at a Copenhagen bank.
It reads share purchase agreements, notarial deeds, probate records and wills, tax returns, payslips and employer letters, custodian and bank statements, property contracts and exchange statements, in their original language with an English reading beside them. Each kind of event has its own corroboration standard, for example a sale agreement plus proof of receipt plus one independent source for the sale of a business.
Yes. The Adverse Media agent searches news, court and regulatory sources in the language of each source document. In the sample file it read 412 Spanish, 37 Danish and 96 English articles and showed, with tax IDs and owners, that the one Spanish hit was a different company. It never clears a true match, and private bankers never see its findings.
The Gap agent sizes the unexplained amount in dollars and drafts one request for the single document that would close it; the analyst approves and the private banker sends it. If the client cannot obtain the document, the analyst records an exception with a reason code and the BSA/AML Officer decides with the open amount stated. Over 10% of net worth unexplained after two requests goes to the Head of Financial Crime Compliance.
Yes. The agents read, test, draft and explain; they never submit a narrative, contact a client, clear a true match, close a review or change a past record. The analyst prepares, a different senior analyst checks, and the BSA/AML Officer approves every high-risk client with a reason code and an e-signature.
The enhanced due diligence these describe: 31 CFR 1010.620 for private banking accounts of non-US persons, FATF Recommendations 10 and 12 on customer due diligence and politically exposed persons, the Wolfsberg FAQs on Source of Wealth and Source of Funds, the UK Money Laundering Regulations 2017 and the EU AML Regulation. Your own policy sets the corroboration standards, thresholds and review cycles, and the BSA/AML Officer makes the decision.
The Agentic Solution Engine builds and deploys it from your requirements and documents — your source of wealth policy, risk model and the systems your evidence lives in — and it goes live once every quality gate has passed. First-time setup connects the systems, loads the policy and roles, sets the thresholds and tests the agents on 40 files you already decided; going live needs the Head of Financial Crime Compliance's approval.
Accounts open the same day, and not-in-good-order stops before the custodian sees it.
1-min demoReg BI Compliance ReviewEvery recommendation reviewed overnight; every flag decided by a principal, with evidence.
1-min demoIRA Rollover AnalysisEvery rollover file carries a specific, cited best-interest rationale, ready in minutes.
1-min demoWe'll run Source of Wealth Verification on a sample of your own past enhanced files and their evidence.