Source of funds you
can evidence on file.
Weak source-of-funds and source-of-wealth checks — and CDD gaps — are among the most common SRA AML findings. Reglo keeps the policies, training, and rationale that drive consistent SoF/SoW evidence aligned, so the work shows clearly when files are sampled.
Doing the source-of-funds work isn't enough — the file has to evidence the rationale, clearly and consistently.
File sampling tests how AML controls operate in real matters. The SRA repeatedly finds weak source-of-funds and source-of-wealth evidence, inadequate CDD, and risk assessments where boxes are ticked with no explanation. The fix is being able to justify what was decided. Reglo keeps the policies, guidance, and training that drive good file evidence aligned and understood.
Who this is for
For the teams whose files get sampled
Conveyancing and probate teams
High-frequency transactional work where SoF evidence is tested most often.
MLROs
Confidence that escalation and rationale are recorded consistently across the firm.
Supervisors and fee earners
Clear, current guidance on what good SoF/SoW evidence looks like.
How Reglo helps
From regulatory change to audit-ready
Set the standard, clearly
Keep CDD and source-of-funds policies and practical guidance current, specific, and understood — not generic templates.
Make sure staff understand it
Role-specific training and comprehension tests so fee earners know what evidence and rationale a file needs.
Evidence consistency across the firm
Attestations and training records show staff understood the SoF/SoW approach applied on sampled files.
What file sampling tests
On the file, the SRA looks for
Source of funds and wealth
Evidence and rationale, not just a conclusion that funds are legitimate.
CDD records
Due diligence done and clearly evidenced on the matter.
Risk rationale
Why the matter was rated as it was — and why it was, or wasn't, escalated.
What you get
What strong SoF evidence looks like
Rationale recorded, consistently, across the firm.
Clear, current guidance
CDD and source-of-funds policies that tell fee earners what good evidence and rationale look like.
Role-specific training
Training targeted at the teams whose files are most often sampled — with comprehension evidence.
Consistent escalation
Support for recording why a matter is or isn't escalated to the MLRO, and the reasoning behind it.
Evidence that holds up
Training and attestation records that back the SoF/SoW approach when files are reviewed.
Common gaps firms discover too late
Recurring source-of-funds findings
Tick-box with no explanation
Risk assessment boxes ticked without the reasoning to justify them.
Weak SoF/SoW evidence
A conclusion on the file without the documents or analysis behind it.
Unrecorded escalation decisions
No record of why a matter was or wasn't escalated to the MLRO.
Evidence Reglo helps you keep ready
Back your file evidence with the framework
- Current CDD and source-of-funds policies with practical guidance
- Role-specific training records for transactional teams
- Comprehension evidence that staff understood the approach
- Attestations linking staff to the current procedures
- A trail connecting policy, training, and acknowledgement
- Version history for source-of-funds guidance updates
Current capability vs roadmap
What Reglo is — and isn't
Reglo strengthens the framework behind good file evidence — it doesn't sit on the file.
Reglo provides
- CDD and source-of-funds policies, with mapping and version control
- AI redline drafting and gap analysis (you approve)
- Role-specific training and comprehension tests
- Attestations and an audit-ready evidence trail
Reglo is not
- A place to capture source-of-funds documents on individual files
- A CDD verification or matter-scoring tool
- A store for client files or matter records
This replaces overhead — it doesn't need a new budget line.
Retrospective file reviews and remedial training after a finding are expensive and disruptive. Keeping source-of-funds guidance current and understood across teams reduces the risk of that outcome.
- Hours of policy admin, attestation chasing, and evidence assembly handed back to the firm — not a new headcount.
- Typically less than the billable time firms lose to manual policy updates and audit preparation each month.
- Guided onboarding: we migrate your policies and map your sources — no IT project, no six-month rollout.
Common questions
Why is source of funds such a common SRA finding?
Because file sampling tests practice, not paper. The SRA repeatedly finds weak source-of-funds and source-of-wealth evidence, CDD gaps, and risk assessments ticked without explanation. The key is being able to justify what the file says.
Does Reglo capture source-of-funds documents on each file?
No. Reglo keeps the policies, guidance, and training that drive good file evidence aligned and understood — it doesn't sit on individual files or store matter records. The source-of-funds evidence itself stays in your case-management system.
How does Reglo help with escalation decisions?
Reglo keeps the policy and training on when and how to escalate current and understood, with comprehension evidence — so fee earners know to record why a matter is or isn't escalated to the MLRO.
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See how Reglo would work for your firm
Book a demo and we'll show you how Reglo keeps your policies, training, attestations, and audit-ready evidence aligned — against your real compliance setup. Your team stays in control; humans approve every change.