Overview
The Source of Funds review is generated automatically in Legl once a client has submitted their request. It presents the evidence your firm needs to assess the client's source of funds, surfacing the most important information first. A PDF report is also available for your records.
Where you will see this
The Source of Funds review is accessible from the client's Engage request in Legl, under the Source of Funds section.
It becomes available once the client has submitted their request.
The full PDF report is also available within the same section for download and record-keeping.
What the review contains
The Source of Funds review typically includes:
The client's declared source of funds and the amount they have accounted for
Whether the declared amount meets the transaction requirement
Any discrepancy between the declared amount and the transaction value, along with the client's explanation where one was provided
Bank statement evidence, either from open banking or a manually uploaded PDF
AI-extracted bank statement analysis, including regular income, large transactions, account balance trends, and higher-risk transaction indicators
Responses to any automated follow-up questions sent to the client (open banking submissions only)
Open banking vs manual PDF submissions
The review experience differs depending on how the client provided their bank data:
Open banking: includes the full AI analysis and any SoF Signals responses where high-risk transactions were detected and the client was asked to explain them.
Manual PDF upload: includes AI analysis where extraction was successful. Where analysis could not be completed, the review will display a message prompting manual review of the uploaded document. SoF Signals automated follow-ups do not apply to manual PDF submissions.
Understanding discrepancies
A discrepancy occurs when the client has not declared sufficient funds to cover the full transaction amount. Common reasons include:
The client is splitting funding across multiple people or accounts
Part of the funds will come from a third party, such as a family member
The client has not yet received all funds (for example, a property sale has not yet completed)
Where a discrepancy exists, the client's stated reason is shown in the review. Your firm should assess this reason and determine whether further information is required.
Automated follow-up questions (SoF Signals)
If Legl detected unusual or high-risk transactions in the client's open banking data, such as large cash deposits, cryptocurrency activity, or non-GBP transactions, it will have automatically sent the client follow-up questions. The client's responses are included in the review and form part of the evidence available to your firm. You do not need to have taken any action to trigger this.
ℹ️ Further guidance
See Understanding Source of Funds Signals for more detail on how this works.
What you need to do
Review the evidence and assess whether it is sufficient for your firm's AML obligations.
Where a discrepancy is present, review the client's explanation and determine whether additional information is needed.
Where AI analysis could not be completed, manually review the uploaded bank statement or supporting document.
Record your firm's determination in your case management system or internal records, in line with your firm's AML procedures. The Legl review is the supporting evidence. It does not update automatically to reflect your conclusions.
Important information
Legl does not verify or validate a client's stated source of funds. All compliance decisions sit with your firm.
The review surfaces the most critical information first. The full PDF is also available for your records.
Automated SoF Signals follow-ups apply to open banking submissions only. Manual PDF submissions do not trigger automated follow-up questions.
Where AI analysis could not be completed, the review will indicate this and prompt manual review.
Your compliance determination should be recorded in your firm's own systems. It does not feed back into the Legl review automatically.