Show Me The Money
In Episode 6 of Beyond the Check: Brick by Brick, host Rhian Del-Valle is joined by Luke Haddon, MLRO at Keystone Law, Mike Ross, Head of Risk & Compliance at Anderson Strathern, and Jon Parish, Compliance Manager at Credas, to explore one of the trickiest parts of client due diligence: source of funds and source of wealth.
What does a genuinely robust source of funds process look like, beyond requesting six months of bank statements? Where does source of funds end and source of wealth begin? And can technology ever replace the human judgement needed to spot when something doesn’t add up?
The discussion covers:
Why “reasonable measures” have evolved even though the regs haven’t
✓ Moving from box-ticking to a surgical, risk-based approach
✓ The three pillars: information, verification and contextual questions
✓ Common red flags, and how to build a culture that acts on them
✓ Escalation: what happens when something doesn’t add up
✓ Source of funds vs source of wealth, and where the line sits
✓ Building a defensible audit trail
✓ Technology, open banking and the limits of automation
As Luke Haddon explains during the episode, “Your instincts only click if you ask enough questions to trigger something for it to go off.”
Whether you’re a conveyancer, compliance professional, MLRO, COLP, risk manager or legal sector leader, this episode offers practical insights into asking better questions and building a more defensible approach to source of funds and source of wealth.
🎤 Guests:
- Luke Haddon, MLRO, Keystone Law
- Mike Ross, Head of Risk & Compliance, Anderson Strathern
- Jon Parish, Compliance Manager, Credas
Hosted by Rhian Del-Valle, Director of Enterprise & Partnerships at Credas.
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