Card game aims to encourage better documented analysis of source of funds
Summary
A compliance training card game has been developed to help firms improve how they document source of funds decisions. Its creators say the main weakness is often not the underlying analysis, but the failure to record the reasoning clearly and consistently for audit and compliance purposes.
Why it matters
For residential property surveyors involved in transactions, source of funds checks can form part of wider AML and conveyancing-related due diligence. Better documentation reduces compliance risk and helps firms evidence decision-making during audits or reviews.
Key points
- Created by compliance consultants Tom Lyes and Steve Brett
- Aims to improve written analysis of source of funds decisions
- Focuses on translating reasoning into clear documented evidence
- Designed for fee earners and support staff in facilitated 60-90 minute sessions
- Source of funds remains a recurring issue in SRA desktop audits
Organisations:
Armalytix, Tom Lyes Consultancy, E3 Compliance Training, SRA
Regulations:
source of funds, SRA desktop audits
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