Overview
A Commercial Source of Funds request collects information about where a business's funds originate. The business, or a third party they delegate to, declares one or more sources and provides supporting evidence for each. Together with bank statement analysis and financial information drawn from the company report, this forms the evidence used to support your firm's AML review.
What information is requested for each source
Click each source to open.
Asset sale proceeds
Asset sale proceeds
We will need the sale documents and proof showing the business received the asset sale proceeds.
What type of asset was sold?
Amount
Do any of these funds come from outside the UK? (Yes/No)
Has the business received these proceeds yet? (Yes/No)
Buyer name
Completion date
Document evidence upload: the sale agreement, completion statement and evidence showing the proceeds arriving in the business account
Bank or commercial loans
Bank or commercial loans
We will need the loan documents and evidence showing the drawdown into the business account.
Lender name
Type of financing
Amount
Do any of these funds come from outside the UK? (Yes/No)
Has the business received this funding yet? (Yes/No)
Facility or account reference
Document evidence upload: the facility letter, loan agreement, lender confirmation and evidence of the drawdown into the business account
Business profits
Business profits
We will need the business accounts, bank statements and supporting evidence showing how the profits were retained.
Name this source
Business name
Do any of these funds come from outside the UK? (Yes/No)
How much of these retained profits will be used?
What generated these profits?
Document evidence upload: company accounts, management accounts, tax returns and business bank statements showing how these profits were retained
External investment
External investment
We will need the investment documents and proof showing the capital was received by the business.
Investor name
Type of investor
Amount
Do any of these funds come from outside the UK? (Yes/No)
Has the business received this investment yet? (Yes/No)
Investment structure
Document evidence upload: the investment agreement, subscription documents, updated cap table and evidence of the funds received by the business
Shareholder/director funding
Shareholder/director funding
We will need evidence of the shareholder or director contribution and any supporting corporate approvals.
Who provided the funding?
What is their relationship to the business?
Amount
Do any of these funds come from outside the UK? (Yes/No)
Has the business received this funding yet? (Yes/No)
How was the funding structured?
Document evidence upload: supporting documents such as the director loan agreement, share subscription documents, board resolution and transfer evidence
ℹ️ Important
For every source where 'Yes' is selected to confirm the funds have been received, a prompt to connect a bank account or upload statements for that source will appear at the next stage of the request.
Delegating a source
Each source can be delegated to a third party to complete on the business's behalf, using the Delegate source option. Their responses and uploaded evidence are included in the same Commercial Source of Funds review.
The recipient of the original Source of Funds request is responsible for sending the delegation to the delegated individual and following up with them. Legl does not email the delegated individual on your behalf.
The Source of Funds request cannot be completed until the delegated individual has completed their source.
Bank statement evidence
Alongside the declared sources, bank statement evidence is collected to support the review. This can be provided in one of two ways:
Open banking: the bank account is connected directly, providing real-time, verified transaction data. Legl presents this option first.
Manual PDF upload: a PDF bank statement is uploaded instead. This option is available where open banking cannot be used or is not preferred.
Your firm can configure the historic statement range to 3, 6, 12 or 24 months. By default, this is set to 12 months.
For both methods, Legl's AI analysis automatically extracts the following from the bank statement data:
Regular incoming transactions: recurring income streams across accounts
Regular outgoing transactions: recurring outgoings across accounts
Largest one-off transactions: significant individual credits or debits
Account balance trends: how balances have changed across accounts over the statement period
Higher-risk transactions: activity associated with elevated risk, such as non-GBP deposits, cash transactions, or cryptocurrency activity
ℹ️ Important
Where analysis cannot be completed, the review will display a message indicating that manual review is required.
24 months of bank statements is only pulled where the business's bank allows for it.
Where a bank account is connected via open banking and Legl detects high-risk transactions, Legl may automatically send follow-up questions (SoF Signals). The responses are included in the Commercial Source of Funds review.
Open banking transaction data
When a bank account is connected via open banking, Legl retrieves the transactions over the required period. Transactions are organised using a classification system that assigns a category and subcategory to purchase-related activity, giving additional context to each transaction and helping your firm more efficiently understand the nature of incoming and outgoing funds.
Transaction classification is currently supported for banks in the UK, Ireland, and France.
Supporting documents
Every source includes a document evidence upload for the relevant supporting documents. Your firm can configure whether a supporting document upload is mandatory for each source in the workflow settings.
Supported file types are PDF, JPEG, JPG, PNG, GIF and TIFF. Password-protected PDFs cannot be uploaded. Documents uploaded as supporting evidence cannot be analysed by the AI but may be used to support the review.
Important information
The historic statement range (3, 6, 12 or 24 months) is configured by your firm in the workflow settings. The default is 12 months.
24 months of bank statements is only pulled where the business's bank allows for it.
AI analysis applies to both open banking and manual PDF submissions. Where analysis cannot be completed, the review will indicate this and prompt manual review.
SoF Signals automated follow-up questions apply to open banking submissions only. Where a PDF bank statement is uploaded manually, these are not sent.
Legl does not make compliance decisions. Assessing whether the evidence is sufficient for your firm's AML obligations is your firm's responsibility.