Funds versus wealth

A customer who receives a request and cannot tell which term is being asked should treat the two as separate checks. The evidence that answers one does not automatically answer the other.

The two definitions, side by side

Put side by side, the distinction is between a payment and a person. Source of funds concerns the money moving into a particular transaction. Source of wealth concerns a person's total assets and how they were acquired. The glossary does not define customer due diligence or enhanced due diligence, terms that operators often use in their requests. Those descriptions sit elsewhere in the Commission's guidance and relate to the level of checking, not to the evidence itself. The two definitions quoted above are the only definitions of these two terms in that glossary.

Which question a bank statement answers

A bank statement is the natural answer to source of funds. If the transaction was a deposit funded by salary, a transfer from another account in the customer's name, or the proceeds of a sale, the statement shows the route. Operators checking source of funds are usually looking for the route into the gambling account, not a general balance. What a single statement rarely does is answer the second term. A current account balance or a recent incoming payment says little about how a person accumulated assets over years. The Gambling Commission does not prescribe a fixed list of acceptable documents; each operator sets its own list, so a statement may satisfy the first request and fail the second.

Which question needs a longer answer

The wealth question almost always needs a longer answer. The definition asks for the origin of a person's total assets and an indication of their volume, not the origin of one payment. That means the operator will want an account of how wealth was built up: earnings over time, property, investments, business income, inheritance, or a combination. No single recent document answers it in most cases, because the request is about a history. A customer who sends only the statement showing the deposit that triggered the review can expect a follow-up, since the two questions call for different material. Again, the operator decides which specific documents it will accept.

Why one request can follow the other

One request can follow the other without anything having gone wrong. An operator may first ask for source of funds to confirm that a deposit came from the customer's own salary or savings. Once that is established, it may ask for source of wealth because the size of the deposit, the amount deposited across the account, or the pattern of gambling appears out of line with what the operator already holds on the customer. The question is not an allegation. A deposit funded by the sale of a house answers source of funds; explaining how the house was bought answers the wealth question. Both can be required in the same review, and a request for the second does not mean the first answer was rejected.

Not the same thing as a financial vulnerability check

The financial vulnerability check under social responsibility code provision 3.4.4 is a separate requirement from either source of funds or source of wealth. It is based on customer-specific public record information, and it exists to identify customers who may be at risk of harm. An operator can run that check without asking for a statement. Equally, a request about a customer's overall wealth is not a demand for the public-record information used in the 3.4.4 check. The documents are different, the legal basis is different, and the Commission's glossary definitions apply only to the anti-money-laundering terms.

A customer unsure which request they have received should ask the operator to name the term exactly. If the words do not match one of the two definitions quoted above, the request is coming from a different part of the rules.