Clarity in source of wealth due diligence requirements in Singapore

Singapore has been recognised as the premier financial hub, contributed by its political stability, strong rule of law, and a robust regulatory environment.

The integrity of Singapore’s wealth management sector follows rigorous standards for source of wealth due diligence. As regulatory expectations evolve, understanding adequate identification, corroboration, and documentation a client’s source of wealth is essential for maintaining a compliant and sustainable wealth planning structures, such as family trusts.

This article clarifies Singapore’s current approach to source of wealth (SOW) verification, outlines the key differences between SOW and source of funds, and highlights practical approach for maintaining effective customer due diligence (CDD) frameworks.

Understanding source of wealth due diligence

Source of wealth refers to how a client accumulated their overall wealth (which is distinct from the source of funds) over time, through business ownership, employment, investments, inheritance, or other legitimate means. Verifying the origin of the client’s overall wealth enables financial institutions to assess whether a client’s financial profile aligns with their declared wealth and risk category.

Singapore’s Monetary Authority of Singapore (MAS) expects financial institutions to apply the principles of materiality, relevance, and prudence when conducting SOW due diligence. These principles guide how much information is required, what documentation is sufficient, and when further inquiry is warranted.

Under this framework, financial institutions, such as trust companies and other regulated entities must:

• Obtain and assess the plausibility of declared SOW information.
• Corroborate the information with independent evidence where appropriate.
• Document the rationale supporting their conclusions.
  
  

Industry guidance and best practices

In May 2025, updated industry guidance clarified expectations for source of wealth due diligence in Singapore. The paper outlined the importance of a risk-based approach and reinforced the distinction between source of wealth and source of funds.

Key takeaways include:

• Risk-based depth of inquiry: Enhanced due diligence (EDD) should apply to higher-risk clients such as politically exposed persons (PEPs), those with complex corporate structures, or clients from high-risk jurisdictions.
• Plausibility assessment: The declared SOW must be consistent with a client’s known profile, occupation, and transaction behaviour.
• Independent corroboration: Public filings, financial statements, tax returns, and sale agreements can help verify the legitimacy of the SOW.
• Documentation discipline: Institutions should record not only what documents were reviewed but also how the information was assessed and why it was considered sufficient.

Distinguishing source of wealth from source of funds

Although the two terms are often used interchangeably, they serve distinct purposes in the context of customer due diligence in Singapore:

• Source of wealth: Explains how a client accumulated their overall net worth. It covers long-term wealth generation and provides context for the client’s financial position.
• Source of funds: Relates to the specific funds deployed for a particular account or transaction.

Both must be assessed, but they require different evidence and verification steps. Understanding this distinction helps prevent gaps in compliance reviews and reduces the risk of regulatory scrutiny.

Ongoing monitoring and senior management accountability

SOW due diligence is not a one-off process. Ongoing monitoring is required to ensure that the client’s profile are kept updated and that transactions during the lifecycle of the account remain consistent with the client’s profile.

Financial institutions should:

• Review SOW assessments when clients’ circumstances or business activities change.
• Obtain updated corroborating documents where appropriate.
• Investigate discrepancies or red flags such as unexplained wealth growth or inconsistent transaction patterns.

While operational tasks may be delegated, senior management remains accountable. Boards and compliance heads must demonstrate that systems, controls, and oversight processes are effective in managing financial crime risk.

Documenting and corroborating source of wealth

Proper documentation provides a transparent audit trail that supports regulatory compliance and internal assurance. MAS emphasises that documentation should demonstrate not only what was collected, but how the institution conducted its plausibility assessments. Simply put, lack of documentation alludes lack of assessment in a corporate setting.

Examples of corroborating documents include:

• Employment or business income records
• Share sale or property disposal agreements
• Dividend statements or audited financial reports
• Tax returns or evidence of declared income
• Independent verification from reliable third-party sources

The amount and type of documentation should be proportionate to the client’s risk level, the complexity of their wealth, and the nature of their relationship with the institution.

Fraud risk and quality assurance

Institutions must remain alert to the increasing sophistication of fraudulent or tampered documents. Verification processes should include:

• Cross-checking information against public or third-party databases
• Confirming authenticity through official issuers or trusted intermediaries
• Establishing procedures for escalation and review when anomalies arise

Regular internal audits and peer reviews help ensure that CDD standards remain robust and consistent across the organisation.

Key takeaways

• Source of wealth verification is a cornerstone of Singapore’s financial integrity framework.
• A risk-based, well-documented approach ensures that due diligence meets MAS expectations.
• SOW and source of funds are distinct but complementary elements of client assessment.
• Ongoing monitoring is essential to detect and address changes in client circumstances.
• Harneys Fiduciary provides expert support to simplify complex SOW documentation and compliance processes.

FAQs: Source of Wealth Due Diligence in Singapore

What evidence is required to verify a client’s source of wealth?
The evidence depends on the client’s risk profile and type of wealth. Common documents include payslips, Transaction advice, audited accounts, sale agreements, and tax filings. The goal is to establish a plausible and well-supported assessment.

What happens if corroborating documents are unavailable?
Institutions should document the reasons, explore alternative evidence, and assess whether it is reasonable to rely on the client’s declaration. The absence of documentation may not, on its own, lead to unverified acceptance.

How often should SOW due diligence be refreshed?
Typically, during periodic CDD reviews or when significant changes occur, such as new investments, changes in occupation, or increased transaction volumes.

How can institutions distinguish between SOW and SOF during client onboarding?
SOW assesses overall wealth accumulation, while SOF examines the origin of specific funds. Both must be addressed, with supporting evidence documented separately.

Why is strong CDD and governance critical for maintaining a sustainable trust structure?

Robust customer due diligence (CDD) and ongoing governance are fundamental to the long-term stability of any trust structure. Weak or incomplete CDD can lead to serious consequences, including bank account freezes or closures, heightened regulatory scrutiny, and in some cases the forced termination of trust arrangements.

As licensed trustees, Harneys Fiduciary places a strong emphasis on proportionate, risk-based CDD, proper source of wealth documentation, and continuous record-keeping. This approach helps ensure that trust structures remain operationally viable, regulator-ready, and acceptable to banks and counterparties over time.

By embedding strong governance and due diligence standards from the outset, Harneys Fiduciary supports more sustainable and compliant trust solutions that protect both clients and fiduciaries from avoidable regulatory and operational disruption.