Source-of-Funds vs Source-of-Wealth: A Simple Checklist for iGaming Teams

When a player funds an iGaming account, that money has a story. Your job is to figure out whether the story makes sense, and whether you need proof.

That’s where source-of-funds checks come in, and where many operators get tripped up. They ask for the wrong thing, ask too late, or accept “proof” that wouldn’t stand up to a regulator review.

This guide breaks down the difference between Source-of-Funds (SOF) and Source-of-Wealth (SOW), then gives a simple, practical checklist for what to ask, what to accept, and when to escalate.

Source-of-Funds vs Source-of-Wealth

Think of money like water.

• Source of Funds (SOF) is the water in the glass right now. Where did this specific deposit come from? A salary payment, a business payout, a property sale, crypto liquidation, a loan?
• Source of Wealth (SOW) is the tap and the plumbing. How does the player generally build and hold wealth over time? Employment, business ownership, investments, inheritance, long-term savings?

SOF is often narrower and faster to verify. SOW is broader and usually comes into play for higher-risk customers, large volumes, or ongoing high-value activity.

If you want a quick reference to the concepts and common documents, this overview of Source of Funds (SOF) and Source of Wealth (SOW) is a helpful baseline.

Why SOF and SOW matter more in iGaming than most industries

In many businesses, customers pay for a product and leave. iGaming is different. Funds can move in and out quickly, and players can deposit, play a little, then withdraw.

That makes iGaming attractive for criminals trying to “wash” money through normal-looking activity, and for fraudsters using stolen cards or mule accounts.

Regulators expect a risk-based approach that matches your product, markets, and player behavior. Industry best practice guides (like the American Gaming Association’s AML best practices for 2025) repeatedly come back to the same themes: documented controls, customer due diligence, and escalation when patterns don’t match the customer profile.

SOF and SOW fit right in the middle of that.

A simple SOF checklist: what to ask players (and what you’re really testing)

You’re not collecting paperwork for fun. You’re testing consistency: does the player’s funding behavior match what they say about themselves?

Start with questions that are easy to answer and hard to fake.

What to ask (use plain language)

1) What is the money for this deposit from?
Give selectable options first (salary, savings, business income, investment sale, inheritance, loan, crypto sale), then allow a short free-text explanation.

2) How did the money reach you before it reached us?
You’re looking for the chain, not a life story. Example: “Monthly salary paid into Bank A, I transferred to my card, then deposited.”

3) What’s your occupation and employer (or business type)?
You’re checking whether their stated income source matches their risk signals.

4) Is anyone else funding this account, or are you using someone else’s card/wallet?
This question surfaces third-party funding, which is a common weak point.

5) Is this level of play typical for you?
This is useful when behavior changes, like sudden high deposits after months of low activity.

When to ask (triggered, not random)

Most teams get better results when SOF is trigger-based. Common triggers include:

• A single large deposit or a sharp jump in deposit size
• Repeated deposits in a short window
• Deposit behavior that doesn’t match gameplay (for example, “money in, money out”)
• Withdrawal requests soon after funding with little play
• High-risk payment methods, locations, or unusual device patterns

Good SOF questions work best alongside monitoring. If you’re building your process, this guide to simple transaction monitoring rules for small iGaming operators pairs well with SOF and SOW decisions.

What to accept as SOF and SOW evidence (and what usually isn’t enough)

A useful rule is: accept documents that show ownership, origin, and movement of funds, and reject items that only show a number without context.

Quick acceptance table (practical, not legal advice)

Claimed source	Usually acceptable evidence	What to check before accepting
Salary or wages	Recent payslip plus bank statement showing salary credit	Name matches player, income level fits activity, dates are recent
Savings	Bank statement history showing build-up	Balance growth makes sense, no unexplained large incoming transfers
Business income	Company registration plus bank statement showing business receipts	Player link to business, revenue looks plausible, not just a screenshot
Property sale	Signed sale agreement and proof of proceeds in bank	Timing matches, amounts match, buyer and seller details look real
Investment sale	Broker statement and bank proof of transfer	Asset sale date, payout date, account ownership
Inheritance or gift	Legal letter or estate document plus bank credit	Relationship and timing make sense, check for repeated “gifts”
Loan	Loan agreement plus funds credited to player	Lender identity, terms look real, avoid “friendly loan” with no detail
Crypto sale	Exchange statement plus fiat payout to bank	Named exchange, transaction trail, avoid “wallet screenshot only”

What to avoid accepting (unless verified another way)

• Screenshots without supporting statements (easy to edit)
• A single page with a balance but no transaction history
• “My friend sent it” with no documentation
• Crypto wallet screenshots with no exchange record and no fiat trail
• Documents with mismatched names, cropped identifiers, or missing dates

If your market touches Australia, AUSTRAC’s guidance around source of funds and source of wealth is a useful read because it shows how regulators think about these checks during reform and supervision.

When to escalate: the red flags that should trigger EDD or a case

Escalation is the difference between a routine check and a real risk response. You don’t need to treat every oddity like a crisis, but you do need consistent rules.

Escalate to Enhanced Due Diligence (EDD) or your MLRO when you see:

Mismatch red flags

• Player claims low income, but deposits and withdrawals are consistently high
• Player claims “savings,” but statements show frequent large third-party transfers
• The explanation changes across chats or tickets

Transaction pattern red flags

• Funding, minimal play, rapid withdrawal patterns
• Many small deposits that look structured to avoid checks
• Repeated reversals, chargebacks, or failed payment attempts tied to new cards

Third-party and control red flags

• Someone else paying into the account
• Multiple accounts tied to the same device or payment instrument
• The player refuses documents but keeps increasing activity

What “escalate” should look like in practice

Keep it simple and documented:

• Pause or limit withdrawals when policy allows, pending review
• Request one additional proof that addresses the gap (not a shopping list)
• Log a clear case note: what triggered the review, what you asked, what you received, what decision you made
• If suspicion remains, route to the right reporting path in your jurisdiction (and keep discussions internal)

A real-world-style example (so your team can picture it)

A player deposits $8,000 over two days after months of $100 deposits. They play lightly, then request a $7,500 withdrawal.

• SOF question: “What is this deposit money from?”
• Player answer: “Savings.”
• Evidence received: one cropped screenshot showing a large balance.

At this point, “savings” isn’t proven. A better next step is a bank statement showing buildup or a recent inflow source (salary, investment sale, business payout). If the statement shows multiple third-party inbound transfers, you’ve got a stronger reason to escalate.

Treat SOF and SOW as a consistency test, not a paperwork hunt

SOF explains a transaction, SOW explains the bigger financial picture, and iGaming businesses that grow fast need both to stay on the right side of risk.

If your source of funds process is trigger-based, evidence-led, and backed by a clear escalation path, you’ll move faster with less friction, and you’ll be ready when regulators or partners ask, “How do you know this money is clean?”

Want your checklist to work in real life? Train support teams on the questions, train compliance teams on acceptance rules, and make escalation a normal workflow, not a panic button.