Head of practice
Head of Corporate Law and Fintech Practice. Expert in the creation and reorganization of companies, support of M&A transactions, as well as legal support for opening and running a business in the EU, Asia, and North America.
Preparation of POF/SOW and the AML package for the bank
A few years ago, to open an account or conduct a large transaction, it was enough for the bank to receive a basic package of the client’s documents. Today, the situation has changed drastically. Almost every international bank, payment system, or financial institution conducts an in-depth AML check and requires confirmation of the source of funds and the client’s wealth.
It is precisely because of insufficient or incorrectly prepared documentation that thousands of applications for opening accounts are rejected every year. Moreover, the lack of convincing evidence of the source of funds can lead to account blocking, transaction delays, or additional checks by the bank.
Therefore, preparing a high-quality POF (Proof of Funds), SOW (Source of Wealth), and AML package today is not a formality, but a mandatory condition for working with the international banking system.
What are POF and SOW
Many clients mistakenly believe that they are the same thing. In reality, banks analyze different aspects of the client’s financial history.
POF (Proof of Funds) confirms the origin of specific funds that are used for a particular transaction or are currently in an account.
SOW (Source of Wealth) explains how the client formed their overall capital throughout their life or business activities.
Most often, the sources of wealth can be:
- business activities;
- dividends from companies;
- sale of a business;
- salary;
- investment activities;
- sale of real estate;
- inheritance or gifting.
The bank must understand not only the origin of a specific amount but also the logic of forming the client’s entire capital. That is why even successful entrepreneurs often face additional questions from compliance departments.
When a bank requests an AML package
An in-depth check can be conducted both when opening an account and in the process of further servicing.
Most often, additional documents are requested in cases of:
- opening an account abroad;
- conducting a large international transaction;
- receiving funds from the sale of a business;
- investment operations;
- working with crypto assets;
- opening a private banking account;
- making cross-border transfers.
Banks pay special attention to analyzing clients with international business structures, significant turnovers, or a complex history of capital formation.
Therefore, it is advisable to prepare a high-quality AML package even before contacting the bank.
| Document | Main purpose | Example of confirmation |
|---|---|---|
| Proof of Funds | Confirmation of specific funds | Bank statement, sales contract |
| Source of Wealth | Confirmation of the origin of wealth | Financial reporting, dividends |
| AML Package | General compliance check | Corporate and financial documents |
| Source of Income | Confirmation of income | Salary, business income |
What mistakes clients make most often
Even with completely legal sources of income, banks can question the origin of funds due to the insufficient quality of the documents.
The most common problems are:
- lack of a logical connection between documents;
- incomplete package of confirmations;
- use of outdated documents;
- inability to explain the movement of funds;
- lack of confirmation of tax payments.
Especially difficult are cases where capital was formed over many years through different companies, investment projects, or international structures.
In such situations, it is important not just to provide documents, but to properly build the history of the origin of funds and assets for the bank.
How “Prikhodko & Partners” helps prepare an AML package
The Prikhodko & Partners team regularly supports clients during bank compliance in Europe, the UK, Switzerland, Canada, the UAE, and other financial centers.
We start with an analysis of the asset structure, sources of income, and the future purpose of using the funds. After that, we form an individual package of documents that meets the requirements of a specific bank or payment institution.
Prikhodko & Partners specialists help prepare Proof of Funds, Source of Wealth, Source of Income, explanatory memorandums, corporate documentation, and other confirmations that may be needed during an AML check.
Our team has special experience in supporting entrepreneurs, international investors, owners of holding structures, crypto investors, and private banking segment clients. Thanks to the combination of tax, corporate, and banking expertise, we help clients pass even the most complex checks by financial institutions.
In many cases, a properly prepared AML package allows not only opening an account but also avoiding future requests, payment delays, and the risk of blocked funds.
Have you received a request from a bank to confirm the source of funds (Proof of Funds) or wealth (Source of Wealth)? Do not risk your account and capital. Contact the international lawyers of Prikhodko & Partners for competent preparation of an AML package and support of a compliance check.
Calculate the cost of services
1 question
Has the bank sent you a request to confirm the source of funds?
2 question
Are you planning to open an account in a foreign bank (private banking)?
3 question
Do you need legal support to pass AML compliance?
Is a bank statement enough to confirm the source of funds?
Usually no. The bank needs to understand the source of the funds, not just the fact of their presence in the account.
What to do if the funds were earned many years ago?
In such cases, a comprehensive Source of Wealth package is formed using historical documents, tax reporting, and other evidence of capital formation.
Is an AML package required to open a corporate account?
In most international banks, yes. Especially if the company has an international structure, significant turnover, or operates in areas with a high level of compliance risk.
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