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A payslip is not a complete source-of-funds check. Follow the money before you decide.

Charles Archibong

, Co-founder

Review source-of-funds evidence against the particular money and transaction being assessed. A document can support part of the explanation without establishing the full route from economic activity to the funds in question.

Toden illustration of an evidence checklist for a source-of-funds review

Key takeaways

  • Source of funds concerns particular money; source of wealth concerns accumulated wealth.
  • Check what each item supports and what it leaves unexplained.
  • A recorded declaration or identity pass is not independent verification of funds.

Review the explanation for the particular money being assessed, then ask whether the evidence supports that explanation. A payslip might support employment income. It does not, by itself, establish how all the money for a proposed transaction was accumulated or transferred.

This is an operational review method, not a statement of which checks the law requires for your business. Apply the jurisdiction-specific policy agreed with your compliance adviser.

Start with the money, not the upload

Record the amount, currency, intended transaction, customer explanation and relevant dates. Ask a clear question: what activity generated these funds, and how did they reach the account being used?

HMRC distinguishes source of funds from source of wealth (opens in a new tab): the former concerns particular transaction funds, while the latter concerns accumulated wealth. We use those definitions here without extending UK legal requirements to other markets.

A general biography cannot fill a missing transaction explanation. Equally, one incoming bank transfer does not describe the customer's entire wealth.

Map each item to a claim

In an illustrative employment-savings case, the employment record may support the income explanation, account entries may support receipt, and the savings history may explain accumulation. Assess the dates and consistency rather than counting files.

Other explanations need different evidence. An asset sale, inheritance or business distribution should not be forced into an employment checklist.

For each item, record its source, what was checked, the claim it supports and the gap it leaves. An uploaded statement is not automatically authentic, and an authentic statement may still leave the economic origin unexplained.

Request a specific clarification instead of another generic bundle of documents. If the payer differs from the claimed source, ask why. If the dates or amounts contradict the explanation, leave that contradiction visible.

Use an appropriate secure collection channel and minimise unrelated personal information. Route unresolved cases to the person authorised by your policy; do not treat a missing answer as proof of a crime.

Keep the decision understandable

Write what the evidence supports, what remains uncertain and why the resulting action is appropriate. A reviewer should be able to follow the reasoning without reopening every attachment.

Toden can collect customer declarations as part of a configured workflow. Those answers remain customer claims until corroborated. Use the workflow overview to design the questions and review route; do not interpret a completed questionnaire as an independently verified source of funds.

Sources

Charles Archibong

About the author

Charles Archibong

Co-founder

Charles Archibong co-founded Toden. He writes about identity verification, financial technology, and the practical work of building trusted digital services.

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