Source of Wealth - Frequently Asked Questions:

Why are you asking for this information?

• We are required to gather this level of data under The Money Laundering and Transfer of
Funds (Information on the Payer) Regulations 2017 (AML Regulations)

What does the term “source of wealth” mean?

• Source of Wealth is the term used to describe the source of capital of which your overall net
worth derives. This may include regular employment, other regular income generation such
as business interests, or accumulated capital over time. Source of Wealth may typically
describe your business activities, career, and/or hereditary access to wealth.

Do I need to complete every section?

• You should answer all questions and complete all relevant sections in as much detail as
possible.

What does each section cover?

• Section A – This should outline your source of wealth narrative. Please include as much detail
as possible and along a sufficient timeline. You may describe educational achievements,
career profile, business interests or any other factor that has been a contributor to your
overall source of wealth. Approximate dates and monetary values will assist in supporting
your profile.

• Section B – This section refers to ‘politically exposed persons’. If you or a close associate are
a politically exposed individual(s), then please outline the name of the politically exposed
person, the role you/they undertake and your relationship to them. Politically exposed
persons are not just limited to members of parliament (or equivalent). Members of the
judiciary, senior positions within government departments or state-owned enterprises are
also deemed politically exposed positions. If you are unsure whether you or an associate may
be deemed a politically exposed person then contact us for guidance.

• Section C – This section will only be applicable to Fundsmith investments that are held via a
private company or trust (or foundation), or a combination of both. Where your investment
has not been placed in direct individual or joint names, please outline the rationale for
investing via such an ownership structure. Please give as much information as possible and
avoid generic answers that fail to suitably explain the purpose of the chosen investment
vehicle.

• Section D – Outline your estimated annual subscription and/or redemption activity. Please
state the value, type (subscription/redemption) and frequency of your estimated activity.
How do I complete the form if I am retired, unemployed or a homemaker?

If you are retired, unemployed or a homemaker you will still need to complete all the appropriate
sections so that we may have an understating of your overall wealth generation and source of funding.

What happens if I don’t wish to provide this information?

• Under the AML regulations, we are required to request this information from you. The
information you provide will be held on your file, and will not be shared with third parties,
unless strictly relating to your investment.
• In order to correctly comply with the regulations we would be unable to release proceeds to
you, if you decide to redeem your holding, prior to us receiving your completed declaration.

What additional information could you ask me for?

• As there is a need to fully satisfy the AML regulations, there may be occasions where we need
additional information from you, or we can’t get what we need from the declaration you’ve
completed.
• As each request is bespoke, it’s difficult to pinpoint exactly what we may ask for. However, we
will write to you with full details of anything additionally we may require.

My investment isn’t new, why do you need this information now?

• The way in which our industry is regulated is constantly changing and updating regulations
regarding fraud prevention is always at the forefront of any change.
• In order to comply with the AML regulations, we need to understand the source of your wealth
and incoming funds.
• Although this may not have been a requirement when you made your investment, in order to
maintain a high level of fraud prevention and comply with the regulations, this information
will be required for our records.

Aren’t source of wealth and source of funds the same thing?

• They could be, but they may also be different. For example, someone may have generated
their total wealth by building up their own business, but you may also receive inheritance that
is then used to fund a particular transaction, which would be an example of source of funds.

What written evidence is acceptable?

• Please see guidance provided detailing acceptable evidence

GUIDANCE – ACCEPTABLE SOURCE OF WEALTH EVIDENCE

This is not an exhaustive list and other documentation may be acceptable, in case of any doubt
please call our Enquiries Team detailed on the letter.

Source of Wealth Documentary evidence

Income from Employment or

Bank statements clearly showing receipt of most recent regular
Salary per annum;
salary payment from named employer, (within three months)
Employer’s name and address; that include salary payment deposits from your named
and employer; and

Nature of business Pay slips from the last three months (including bonus payments,
where appropriate) clearly showing named employer and
amount received.

Employer’s P60 form

Self-Employment
Formal HMRC Tax computation for the customer from regulated
Name and address of business
accountant clearly showing amount of income received and
Nature of company accompanied by valid current proof of accountant’s regulated
status;
Amount of annual profit

Business Ownership/
Company Profits Copy of latest audited company accounts.

Name and address of Documentary evidence of the nature of business activity and
company turnover, e.g. a letter from a regulated accountant accompanied
by updated proof of accountant’s regulated status.
Nature of company
For existing businesses – the last three months of bank
Amount of annual profit
statements for the business account.
Official business entity
Recent dividend statements.
documentation where
ownership is noted, along with
ownership by any other
individuals

Dividend payment Dividend contract note or equivalent, clearly showing the

dividend details, customer’s name and entitlement.
Date of receipt of dividend
Bank statement clearly showing name of customer, receipt of
Total amount received
funds and name of company paying dividend.
Name of company paying
If the dividend is payable from the customer’s own company:
dividend
Letter clearly showing and explaining dividend details, signed by
Length of time the shares
a regulated accountant on headed paper with current proof of
have been held
the accountant’s regulated status.

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 Set of company accounts clearly showing the dividend details
and the customer’s name and entitlement or equivalent.

Sale of Property One of the following:

Address of property sold Letter from a licensed solicitor or regulated accountant, stating
property address, date of sale, proceeds received, AND name of
Date of sale
purchaser along with the solicitors’ statement of completion.
Total sale amount
Copy of sale contract as well as proof of receipt of funds e.g.
How long property was Bank statement clearly showing receipt of funds and name of
owned? purchaser

Individual’s wealth from the Copies of media coverage (if applicable) as supporting evidence
Sale of a company AND
Address of company sold One of the following:
Name and nature of the A letter detailing the company sale signed by a licensed solicitor
company (principal activity) or regulated accountant on letter-headed paper and
Date of sale accompanied by proof of the accountant’s or solicitor’s
regulated status.
Total sale amount
A copy of the contract of sale, plus bank statement showing
Client’s share of proceeds proceeds received.
Rental Income One of the following:
Address of the property that A letter from a licensed solicitor or regulated accountant, stating
rental income is generated property address, the property value and total monthly rental
from amount; and
Date of Purchase A copy of the rental contract as well as proof of receipt of funds
e.g. bank statement clearly showing receipt of funds and name
Total value of property
of person(s) renting.
How long has the property
been owned and rented?

Rental amount: Monthly/

Annually

Inheritance Evidence that the customer is the inheritor as well as one the
following:
Name of deceased
The Grant of Probate (with a copy of the Will) clearly showing
Date of death
the amount of inheritance.
Relationship to client
A signed letter from a licensed solicitor or estate trustees on
Date inheritance received letter-headed paper clearly indicating the amount of inheritance,
accompanied by current proof of the solicitor’s regulated status.
Total amount received
The Will (if absolute amount is not clearly shown, other
Solicitor’s details
documentary evidence may be required to support this).

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Evidence of deceased’s wealth The Succession Certificate, detailing the sum amount and name
generation (e.g. credible of the inheritor.
sources linking to a business).
Retirement income One of the following:
Retirement date A pension statement clearly showing name of provider, name of
customer, amount and frequency of income
Details of previous profession/
occupation A pension pay slip clearly showing the name of the pension
provider, name of customer, amount.
Name and address of last
(final) A letter from a regulated accountant clearly showing name of
customer, date(s) and amount of retirement income received
Employer
accompanied by current proof of accountant’s regulated status
Details of pension income
A letter from the annuity provider clearly showing name of
source.
provider, name of customer, amount and frequency of annuity
or equivalent

Bank account statements clearly showing name of pension

provider, name of customer and receipt of pension income (for
the last 3 months).

Housewife or Student All the following:

How long has the customer Bank statements clearly showing the name of the individual
been a housewife & what was provider, name of customer and the amount and frequency of
the customer's previous income.
occupation?
Proof of income coming from the other person, with reference
If the customer is a to whether the income source is coming from someone that is
student/housewife then employed or self-employed.
details of income coming from
another person (identity, Evidence of Income from Employment or Self-Employment
occupation and income (above) for the person providing will need to be obtained.
source).

Gift/Donation Documentary evidence of the donor’s source of wealth as

detailed below:
Date received

Total amount of funds

received One of the following:
Reason for gift Letter from an accountant/lawyer confirming the details of the
gift
Relationship to client
Evidence of withdrawal from another bank account
Certified identification
documents for donor Account statements and the documentation identifying the gift
and the identity of the donor.
Donor’s source of wealth

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If the amount is reasonable in
context of family wealth
profile
Divorce settlement One of the following:
Date received Copy of court order clearly indicating the amount of settlement.
Total amount received Letter detailing divorce settlement as well as clearly indicating
the amount of settlement and signed by a licensed solicitor on
Name of divorced partner
letter-headed paper accompanied by updated proof of solicitor’s
regulated status.

Fixed deposit – savings All the following:

Name of institution where Savings statement clearly showing name of customer and
savings account is held amount of funds.
Date the account was Evidence of account start date (letter from account provider or
established first statement) clearly showing name of customer and amount
of funds.
Details of how the savings
were acquired should be Fundsmith may request additional evidential information, in
provided, using this source of relation to the origin of the savings held.
wealth table as a guide.

Redemption of Investments, One of the following:

Sale of Shares
Certified investment/savings certificates, contract notes or cash-
Date funds received/Sale in statements.
Value
Bank statement clearly showing receipt of funds and investment
From which company company name.
Total amount value Signed letter detailing funds from a regulated
Details of how the shares accountant/solicitor.
were acquired should be Redemption Certificate.
provided, using this source of
wealth table as a guide. Legal sale documents or Credible source evidence supporting
sale or Accountant or solicitor verification.

Sale of investments/ One of the following:

liquidation of investment
portfolio Investment/savings certificates, contract notes, surrender
statements or equivalent clearly showing date and amount of
Description of shares/units/ surrender/liquidation/maturity.
deposits
Bank statement clearly showing receipt of funds and name of
Name of seller investment company.
Time period held

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Total sale/liquidation amount Letter detailing receipt of funds from a regulated accountant on
letter-headed paper and accompanied by current proof of the
Date funds received
accountant’s regulated status.
Asset (share) exchange If the assets have been held for less than two years:
Please describe the origin and Provide evidence of the original source of wealth used to acquire
means of wealth generation the assets.
used to acquire the assets.
If the assets have been held for more than two years:

Provide evidence that the assets have been held in the

applicant’s name for more than two years.

Loan All the following:

Date of loan Loan Agreement.
Total amount Loan Statement (for the most recent three months).
Name & nature of loan
provider
Company profits One of the following:
Name and address of Copy of the latest Financial Statements or audited company
company accounts.
Nature of company Documentary evidence of the nature of business activity and
turnover, annual profit figure e.g. a letter from a regulated
Amount of annual profit
accountant/solicitor accompanied by current proof of
accountant’s/solicitors regulated status.

Matured Investment Statement or letter from investment company providing details

of matured/encashed investment.
Details of the investment

Date of Maturity

Amount received and date

Investment and length of

investment

Legal Entities - Corporate One of the following:

(Public or Private)
Copy of latest audited company accounts Documentary evidence
Name and address of of the nature of business activity and turnover, e.g. a letter from
company a regulated accountant accompanied by updated proof of
Nature of business accountant’s regulated status.

Amount of annual profit For existing businesses: the last three months of bank
statements for the business account
Certificate of ownership
Official legal business entity documentation where ownership is
noted, along with ownership by any other individuals.

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When and how was the
business established and
profile of business owners

What has been the

approximate turnover and
profitability of business?

Number of Employees,
Number of Locations & Details
of any international presence

Any further details on

Bankers, Auditors or Lawyers
Other Income Depending on the source of other income one of the below:
Nature of the income Copy bank statements showing income (bank statements within
the last three months)
From whom received
Tax returns

Letter detailing the portfolio from a regulated

accountant/solicitor on letter-headed paper and accompanied
by current proof of the accountant’s/solicitors regulated status.

Real Estate Investment/ Letter detailing the portfolio from a regulated

Portfolio accountant/solicitor on letter-headed paper and accompanied
by an updated proof of accountant’s/solicitors regulated status.