The Solicitors Regulation Authority (SRA) recently reviewed source of funds and source of wealth checks across the conveyancing sector. The findings made uncomfortable reading – of the more than 5800 files reviewed during 2024/2025, 18% showed inadequate scrutiny or source of funds, and 11% had no source of funds check at all.
The problem isn’t a lack of training or will. It’s a workload and capacity issue.
Why source of funds checks are hard to get right
Most firms already know what a good source of funds check looks like: bank statements and other evidence often reviewed line by line, unusual transactions queried, income and spending patterns checked against the client’s story. Knowing what to look for within the evidence presented isn’t usually the issue. Often, judging how a risk based approach should be applied on each file and how deep to go is the challenge.
A large transfer three weeks before completion might fit what you already know about the transaction, or it might be exactly what a regulator expects a fee earner to have queried. Telling the difference could mean reading every line of every statement, for every account a client has provided. Manageable on a straightforward file but often the first thing to get overlooked on a busy caseload with a completion date looming.
What the SRA actually expects
The thematic review didn’t ask for anything beyond existing regulatory and Legal Sector Affinity Group (LSAG) guidance. It asked for that guidance to be applied consistently: a risk-based check, properly documented, with a clear record of what was reviewed and why a firm was satisfied, or wasn’t. The gap the review found isn’t a lack of understanding. In many cases it was the consistent application of the requirements.
Where technology helps
This is a case where the right tool changes the job, not just the speed of it. Open banking already lets clients share verified bank data directly – firms no longer have to piece together multiple documents, questionable screenshots or dog-eared paper statements and hope nothing’s been left out.
The real value is turning that data into something fee earners can act on. Visualising spending patterns and flagging high-value or high-risk transactions turns the task from reading every line to spotting where the risk sits, so fee earners can make informed decisions and spend their time and expertise where it matters.
Amiqus’s source of funds check works this way. It combines open banking data with visual analysis, covering account balances, income and expenditure trends, large transaction detection and cash tracking, so a fee earner can assess a client’s financial position, spot risks and trends without scrolling through statements line by line.
Used well, technology like this also gives firms something the SRA review found many were missing: a dated, exportable audit trail and record of what was checked, rather than something that lives in someone’s memory.
The key question for firms
The SRA’s findings are not necessarily about the adequacy of checks, but about the consistency and effectiveness of source of funds processes across every matter. These processes often fall down not for want of eff ort, but because fee earners are stretched for time and resources. Amiqus helps by giving decision makers trusted, fast and accurate data at their fingertips, in an easily digestible, time- and date-stamped format.
If you’re unsure whether your firm’s processes would stand up to regulatory scrutiny, it’s worth looking at how Amiqus can support compliance before, not after, the SRA comes knocking.
Graham MacKenzie, Director of AML and Economic Crime Risk, Amiqus
More on Amiqus’s source of funds check: www.amiqus.co/source-of-funds
This article was submitted by Amiqus as part of an advertising agreement with Today’s Conveyancer. The views expressed in this article are those of the advertiser and not those of Today’s Conveyancer
