Source of funds requirements
Ogier is committed to ensuring compliance with anti-money laundering laws and regulations through effective Client Due Diligence (CDD). A key element of CDD is to establish source of funds.
Where Ogier is providing legal advice in relation to a financial transaction, or where Ogier is providing administration services to an entity participating in a financial transaction, we need to understand where the cash/assets involved in that transaction come from.
The most straightforward way to help us meet this requirement is to obtain a short statement in writing (e-mail will suffice) from the contributing parties (e.g. investors, settlor, buyer, etc), which covers the following points:
- The type and value of assets being contributed (e.g. US$1,000,000 cash)
- The overall value of the contributor's net wealth* (e.g. US$50m property, stocks, and cash)
- How the assets were generated (e.g. sale of investment property purchased 2005 with employment earnings)
- How the contributor's net wealth* was accumulated (e.g. inheritance, trading profits, bonuses, etc).
- Where the assets were generated (e.g. USA)
- Where the contributor's net wealth* was generated (e.g. North America and EU)
* In certain circumstances, we need to establish the source of wealth of a contributor, in addition to source of funds. Source of wealth relates to the general body of wealth held by the contributing party, beyond just the assets involved in the transaction at hand. We ask for this information alongside source of funds to ensure we reach out for all the information we might need in one go.
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