Chasing clients for ID and source of funds without annoying them

Why this chase is different #

Asking a client for a bank statement is not like asking for a signature. A client who has just been told their offer is accepted hears a request for evidence of where their deposit came from as an accusation, however carefully it is worded.

Fee earners know this, which is why the request often goes out later than it should, in softer language than it should, and is followed up less firmly than any other outstanding item on the file.

The regulator's position runs the other way. SRA guidance updated 28 January 2026 is direct about timing.

It warns that a firm which obtains information without sufficient time to scrutinise it leaves itself open to being exploited by criminals.

What the evidence actually looks like #

SRA guidance gives worked examples by type of source rather than a universal checklist, because the appropriate evidence depends on the risk.

• Employment income

  Payslips or equivalent evidence of employment income, and bank statements showing regular deductions into savings accounts.

• An inheritance

  Documents confirming the beneficiary or beneficiaries, plus bank statements showing receipt.

The hidden cost is the not knowing #

Ask a firm what its source of funds process costs and you get an estimate of the time spent reading documents. The real cost is somewhere else. It is in:

• Working out, per matter, what has been requested and what has arrived.
• Working out whether the thing that arrived last week was ever looked at.
• Working out which matters have been sitting incomplete long enough to be a problem.
• Writing the third request, which requires reconstructing the first two.

None of that is judgement. All of it is done by opening files. And because it is done by opening files, it is done rarely, which means incomplete matters sit undetected until something forces a look.

The same reconstruction problem runs through keeping clients updated and conveyancing admin.

Chasing badly has a client cost too #

The Legal Ombudsman's data for 2025/26 puts the two largest complaint categories here.

Together that is 46 per cent. A client who is asked for the same document twice, or who is asked in January for something requested in November with no explanation of why it matters, experiences both. The chase is not only a compliance obligation. It is part of the service the client is judging.

Firms that handle this well tend to do two things.

Both are decisions about process, not about technology.

What runs on rules #

The line we will not cross #

Nothing here is advice that a particular way of collecting or verifying identity and funds evidence satisfies the Money Laundering Regulations, and no supplier can give you that assurance either. The SRA supervises the firm against its own risk assessment, and the decisions in this area are precisely the ones it will look at.

Identity and financial documents are also sensitive personal data, and how they are handled is a UK GDPR question the firm has to answer for itself.

What is safe to say is that the tracking around those decisions is mechanical, that most firms do it by opening files, and that this is why source of funds work is usually late.

For the full onboarding picture see client onboarding and AML, and the cost of admin time calculator if you want a number to argue with.