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 brings together everything submitted by the client in one place: their declared source of funds, supporting bank statement evidence, and AI-extracted analysis of their accounts.
Report overview
The top of the report shows a summary of the client's submission, including:
Sources added: the source of funds the client declared and the total amount accounted for
Whether the declared amount meets your transaction requirement
Any discrepancy between the declared amount and the transaction value, and the client's explanation where one was provided
Accounts
This section lists all bank accounts included in the report, along with their balances. Accounts are categorised as either Verified (connected via Open Banking) or Manually uploaded (PDF bank statement). Each account shows the bank name, account type, account number, sort code, and balance. Verified accounts also show a total combined balance.
The type of submission affects what is included in the review:
Open banking: includes full AI analysis of the client's transaction data, plus 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.
Bank account insights
This section shows data extracted from the client's verified bank accounts, broken down by:
Declared: the amount the client attributed to this account
Regular incoming transactions across verified accounts
Regular outgoing transactions across verified accounts
Largest one-off transactions across verified accounts
Higher-risk transactions across all connected accounts
Balance trends across verified accounts (chart)
Questionnaire
This section shows the client's responses to the Source of Funds questionnaire, including any supporting documents they uploaded.
Bank statements
This section shows the full bank statements submitted as part of the review, either connected via open banking or uploaded as a PDF.
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.
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
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 case management systems. It does not feed back into the Legl review automatically.