During onboarding al Private Bank A, client C indicated that the account would be initially funded with a transfer from Bank B totaling 50 million USD. On which source of funds should Bank A conduct additional scrutiny? (Select Two.)

When onboarding a high-value client, the institution must scrutinize both the method of the initial funding and the underlying source of the funds. The "Transfer from Bank B" (D) is the direct transaction that must be examined. Furthermore, the risk that this is a "Third-party transfer" (B) must be investigated, as funds coming from an undisclosed third party is a significant money laundering red flag. The bank must verify that the funds originate from an account in the client's name and understand the economic activity that generated the $50 million.

A. Client's verified employment income: This is a component of the client's overall Source of Wealth (SoW), not the specific Source of Funds (SoF) for this transaction, unless the $50M is claimed to be from this income.
C. Client's overall wealth: This is the client's Source of Wealth (SoW). While it must be understood and verified, the immediate scrutiny is on the specific funds being transferred, not the entire wealth profile.
E. Documented sale of client properties: This is a potential legitimate explanation for the source of funds that the bank would seek to verify, not the object of initial scrutiny itself.

1. Financial Action Task Force (FATF). (2009). Money Laundering Vulnerabilities of Private Banking. p. 11, para. 33. "Particular attention should be paid to... understanding the origin of the funds and wealth... especially when the funds are transferred from another institution."

2. ACAMS. (2023). Certified AML FinTech Compliance Associate Study Guide. Chapter 2, Section: Source of Wealth (SoW) and Source of Funds (SoF). The guide distinguishes between SoW (the origin of a client's total assets) and SoF (the origin of the particular funds used for a transaction), emphasizing the need to scrutinize the specific transaction.

3. Wolfsberg Group. (2020). Frequently Asked Questions (FAQs) on Source of Wealth and Source of Funds. p. 4. "SoF is focused on the origin of the funds involved in the business relationship or transaction... FIs should scrutinise transactions to ensure that they are consistent with the FI’s knowledge of the customer."