How far you identify and verify the customer’s source of wealth (SoW) or funds (SoF) must be according to the level of risk involved. The AML/CFT Act requires you to take reasonable steps, according to the level of risk involved, to verify the SoW of SoF using reliable and independent sources.
Where you identify that the origin of your customer’s funds or wealth has come from their beneficial owner(s), it may be necessary, according to the level of risk involved, for you to extend your level of verification to include the SoW or SoF of these persons. However, you do not ordinarily need to obtain and verify SoW and SoF for every beneficial owner where they have nothing to do with the “customer’s” SoW or SoF. There is further information on this topic on pages 16 and 17 of the Enhanced CDD Guideline here: Enhanced Customer Due Diligence Guideline (PDF, 642KB)
Where you identify that the origin of your customer’s funds or wealth has come from their beneficial owner(s), it may be necessary, according to the level of risk involved, for you to extend your level of verification to include the SoW or SoF of these persons. However, you do not ordinarily need to obtain and verify SoW and SoF for every beneficial owner where they have nothing to do with the “customer’s” SoW or SoF. There is further information on this topic on pages 16 and 17 of the Enhanced CDD Guideline here: Enhanced Customer Due Diligence Guideline (PDF, 642KB)