How To Prepare a Clean Source-of-Funds File For iGaming License Reviews

Getting an iGaming license is hard enough without your capital structure holding you back. A messy source of funds iGaming file can slow your application for months or even kill it.

The good news is that regulators usually want the same core things: clear documents, clean money trails, and simple stories that match the numbers. With a bit of planning, you can give them exactly that.

Why Regulators Care About Your Source-of-Funds File

To regulators, your business model is only half the story. The other half is who owns the company and where their money came from.

iGaming is high-risk for money laundering. That is why regulators push so hard on source-of-funds (SoF) and source-of-wealth (SoW) checks. If you want a clear overview of the difference between the two, this guide on source of funds vs source of wealth in international iGaming is a helpful reference.

Most regulators now expect:

• Transparent ownership, including ultimate beneficial owners
• Traceable capital inflows into the business
• Extra comfort where funds come from high-risk areas like crypto, cash-heavy industries, or certain countries

If your file looks uncertain or incomplete, the default reaction is not “approve and hope for the best”. It is “ask more questions, pause, or reject”.

So your goal is simple: give the reviewer no reason to doubt your money trail.

What A “Clean” Source-of-Funds File Looks Like

Think of your SoF file as a story in three acts: who you are, what money went in, and how that money was earned.

A clean file usually contains:

• Identity and ownership
  • Passports or IDs for owners, directors, and key investors
  • Corporate registry extracts and shareholder registers
  • An ownership chart that shows ultimate beneficial owners
• Banking and income proof
  • 12 to 24 months of personal and business bank statements
  • Payslips and tax returns for salary-based funds
  • Audited accounts for companies providing capital
• Deal and transaction documents
  • Share purchase or sale agreements
  • Loan agreements and repayment schedules
  • Investor subscription agreements and proof of payment
  • Inheritance, gift, or property sale documents where relevant

Regulators like the UK Gambling Commission spell out examples of acceptable proof in their source of funds evidence guidance.

If you use crypto or complex structures, expect to add more layers of documentation and explanation.

Step-by-Step: Building Your Source of Funds iGaming File

You do not need to guess your way through this. Treat it like a structured project.

1. Map ownership and funding lines

Start on paper.

• List every shareholder, director, and beneficial owner, with ownership percentages.
• Note who is putting money into the company, in what form, and when.
• Mark any high-risk items, such as crypto, cash-heavy businesses, or offshore structures.

This map becomes your checklist.

2. Create a document checklist for each person and entity

For each owner or investor, set up a simple checklist:

• ID and proof of address
• Bank statements (personal or corporate) for the last 12 to 24 months
• Income proof (salary, dividends, business profits)
• Supporting contracts (loans, share deals, asset sales, inheritances)

Do the same for the applicant company itself: formation documents, bank statements, and any capital injection records.

If your capital mix includes grants, loans, crowdfunding, or alternative finance, you can borrow ideas from broader alternative business financing options to think through what extra paperwork is needed for each source.

3. Write short narratives for each major source

Numbers alone are not enough. Add a short “source story” for each main chunk of capital. Keep it to a few lines:

• Whose money is it?
• How was it earned or obtained?
• Over what time period?
• How did it move into the current bank account?

For example:

“$350,000 of capital comes from Ms. X’s salary and bonuses as a software executive from 2017 to 2024. Saved gradually into her personal account at Bank A, then transferred to her investment account at Bank B. From there, $350,000 was wired to the applicant company on 12 March 2025.”

These short stories help reviewers follow the trail quickly.

4. Organize your folders like an auditor

Messy files waste time and create doubt.

A simple structure could look like:

• 01_Owners
  • 01_Ms_X
  • 02_Mr_Y
• 02_Company
• 03_Investors
• 04_Crypto

Inside each person or entity folder, create subfolders for Bank_Statements, Tax, Contracts, and ID.

Name files consistently, for example: 2024-03_BankA_Personal_MsX.pdf.

5. Tie the numbers together

Now sanity check everything.

• Match every capital injection into the company with a clear source account and documents.
• Check totals: do the owner’s savings or profits actually support the amount injected?
• Flag any large one-off deposits and attach the related contract or explanation.

If you are unsure what good SoF practice looks like in financial services, this broader article on how to verify source of wealth and source of funds offers a solid framework you can adapt.

6. Add professional comfort

Regulators like third-party comfort, especially for larger sums.

Ask your accountant or lawyer to prepare short letters that:

• Confirm the ownership structure
• Summarize the main funding sources
• Confirm that the documents supplied match their records

Be ready to notarize or legalize documents if your target jurisdiction asks for it.

Handling High-Risk Sources: Crypto, Third Parties, Trusts

Some capital will always attract extra questions. Plan for it.

Crypto-originated funds

Crypto is still seen as higher risk. That is why SoF checks here are tighter.

You will usually need:

• Full wallet and exchange transaction history for relevant periods
• KYC records from any exchange you used
• Proof of conversion routes from crypto to fiat
• Bank statements showing fiat receipts into named accounts

For a broader view of how KYC and source checks work in gaming, see this guide on KYC in online gaming.

Third-party investors and family money

If “someone else’s money” is behind your license, regulators want to know who they are and how they earned it.

Provide:

• Investor agreements, subscription documents, or loan contracts
• SoF documents for the investor, not just for your company
• Clear confirmation of who controls the funds and voting rights

Informal family loans without paperwork are risky. Put them on formal terms and document both sides.

Trusts and complex structures

Trusts, foundations, and layered holding companies are not wrong by themselves, but they do raise the bar.

Expect to provide:

• Trust deeds and any amendments
• Lists of settlors, trustees, and beneficiaries
• Board or trustee resolutions that support the investment

If the structure runs across several countries, an external compliance advisor is usually money well spent.

Common Mistakes That Trigger Red Flags

Many failed or delayed applications trip over the same simple issues:

• Partial bank statements or missing pages
• Unexplained cash deposits that do not match declared income
• Mixed personal and business funds with no clear separation
• Ownership charts that conflict with registry extracts or contracts
• Last-minute changes in shareholding or funding with no documents

From the regulator’s point of view, any of these can hint at money laundering risk. That is why many supervisory bodies publish AML and sanctions guidance, such as this overview of AML and sanctions compliance in iGaming, and, in the US context, federal rules on funding unlawful internet gambling.

A bit of extra work before you submit your file is far cheaper than a rejection or a license review later.

Conclusion: Treat Your SoF File Like Part Of The Product

A clean source of funds iGaming file is not side paperwork. It is part of the product you are selling to regulators: a safe, well-governed business with transparent money.

If you map your ownership, gather documents early, write simple funding stories, and handle high-risk sources with extra care, you turn a painful compliance hurdle into a predictable, repeatable process.

Start building that file now, even before you apply, and future license renewals will be much easier.