Why does TrueLayer ask for a source of funds at the beginning of the business relationship?

TrueLayer, as a regulated financial institution, is committed to maintaining the highest standards of compliance with relevant laws and regulations. As such, we are required to verify the sources of funds and wealth associated with the customer’s account and anticipated activity with us from the outset of the business relationship.

This proactive approach allows us to:

• Meet our regulatory obligations: This is a crucial step in fulfilling our anti-money laundering (AML) and counter-terrorist financing (CTF) requirements.
• Understand your financial activities: By understanding the origin of the funds you intend to use, we can ensure that your activities align with our risk appetite and regulatory framework.
• Protect our ecosystem: This helps us to prevent illicit financial activities and maintain a secure and trustworthy environment for all our partners and users.

For clarity, please note the following definitions:

• Source of Funds: Refers to the origin or provenance of the financial resources used in a transaction or held in an account. This includes details about where the funds were obtained, such as income, investments, loans, inheritances, or gifts.
• Source of Wealth: Refers to the legitimate origins of an individual's total assets and net worth. This encompasses various forms of wealth accumulation, such as earnings from employment or business activities, investments, real estate holdings, inheritances, and other lawful means of acquiring assets.

What information is requested during a periodic review?

TrueLayer conducts periodic reviews to ensure that our records are up-to-date and that we continue to meet our regulatory obligations. During a periodic review, we typically request updated information on:

• Your company's directors.
• Your authorised persons.
• Your shareholder register.

Additionally, we may inquire about any material changes to your products, services, or expected transaction volumes. For certain regulated entities, we might also request an updated AML policy or audit information to ensure ongoing compliance.

These reviews are an essential part of our commitment to maintaining a secure and compliant environment for all our partners.