Source of Funds and Source of Wealth

At Le Gallais & Luce (the “Firm”) we are legally required to understand the origin of any funds received from a client or from a third party on their behalf. This requirement applies to both the Source of Funds (SoF) and the Source of Wealth (SoW), which serve distinct purposes in our due diligence process. To assist you, we have put together some examples of documents that we may accept to confirm your SoF and SoW.

“Source of funds” is the activity that generates the funds for a customer (e.g. salary, trading revenues or payments out of a trust). Source of funds related directly to the economic origin of funds to be used in a business relationship or one-off transaction. Information concerning the geographical sphere of the activities may also be relevant.*

“Source of wealth” are the activities that have generated the total net worth of a client (e.g. ownership of business, inheritance, or investments.) Source of wealth is the origin of the accrued body of wealth of an individual. Information concerning the geographical sphere of the activities that have generated a client’s wealth may also be relevant.**

*  **JFSC Handbook for the prevention and detection of money laundering and the countering of terrorist financing: Glossary & Section 3.3.3 Source of Funds – Stage 1.4.

In order to complete our due diligence requirements you will be asked to provide evidence of your source of funds and/or source of wealth. Please have this information and documentary evidence to hand as any delay in providing such documentation may result in Le Gallais & Luce being unable to complete the required transaction or the withdrawal of all our legal services.

Depending on the circumstances of your transaction, we may ask for one or more of the below:

1. Information on your Occupation and Income (i.e. wages, bonus)

• Written confirmation of annual salary (and/or any bonuses) detailing position held, time of employment, from your employer/HR Manager accompanied by a recent pay slip(s).
• If no longer working (retired), please let us know a history of your past employment with evidence if possible.

2. Savings

• Statement from the savings institution and evidence of source of transfers into the savings accounts.

3. Property Sale

• Copy of contract of sale; or
• Confirmation of sale from an advocate/solicitor who acted in the transaction e.g. completion statement.

4. Sale of Investments

• Copy of contract note(s); or
• Confirmation of sale/holding from an accountant/broker.

5. Inheritance

• Copy of Will/Grant of Probate/Letters of Administration; or
• Confirmation of inheritance from an advocate /solicitor/trustee/executor.

6. Company Sale/Dividend

• Copy of contract of sale; or
• Confirmation of sale from an advocate/solicitor/accountant; or
• Copies of any relevant minutes.

7. Divorce Settlement

• Copy of court order; or
• Confirmation of settlement signed by advocate/solicitor.

8. Lottery/Gambling win

• Confirmation from the lottery company; and
• Winnings’ receipt; with
• Corresponding evidence of payment into your bank account.

9. Gifts

• Written Gifting Letter to be provided from third party making the gift, for sample letter, please go to https://www.lgl.je/wp-content/uploads/2019/07/gifting-letter.docx.
• Documentary evidence of the source of funds and source of wealth of the third party making the gift will be required.
• Third parties gifting funds towards a transaction will also be asked to provide their due diligence, for more information please refer to the guidance on Client Identification – Individual:
• https://www.lgl.je/client-identification-individual/.

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