Source of Wealth (SoW) Due Diligence Series | Part 1

What is SoW analysis?

SoW analysis is the process of understanding how a client’s overall wealth has been generated and accumulated over time, not just the origin of funds for a single transaction.

Traditionally, SoW checks have been treated as a one-time onboarding requirement. But as financial crime risks grow more complex and enforcement expectations rise, this approach is no longer sufficient.

Effective SoW analysis goes beyond declarations and documentation. It involves:

Understanding key sources of income and asset accumulation
Reviewing business interests and ownership structures
Corroborating client disclosures using external and public-domain intelligence
Assessing whether wealth patterns align with the client’s profile and activities

At its core, SoW analysis seeks to answer one fundamental question:
Does the client’s wealth make sense given who they are and what they do?

When applied thoughtfully, SoW analysis becomes a foundational element of proactive financial crime risk management, enabling institutions to identify inconsistencies and make more defensible risk decisions.

Read Part 2

Visionary Insights Video

As we step into 2026, our Managing Director Jaideep Mehta shares his perspective on the forces redefining risk & compliance — from AI-led transformation to risk intelligence moving into the boardroom.

The future isn’t reactive. It’s continuous, predictive, and strategic.

Watch the full video to hear his complete perspective.

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Regulatory Updates

AML Regulatory Highlights – Jan 2026

Europe: On 1 January 2026, the European Banking Authority (EBA) completed the formal transfer of all its AML/CFT mandates to the new Authority for Anti-Money Laundering and Countering the Financing of Terrorism (AMLA). AMLA now serves as the EU’s central AML/CFT supervisory and rule-making authority, responsible for binding supervisory convergence, the single AML rulebook, and cross-FIU cooperation across member states. This represents a significant shift from decentralized regime to a unified EU enforcement framework.
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North America: On 21 January 2026, the U.S. Treasury’s Office of Foreign Assets Control (OFAC) imposed new sanctions designations targeting a major Costa Rica-based cocaine trafficking and money laundering network, expanding the use of U.S. sanctions authorities against narcotics-linked networks and associated entities. The action included designations of individuals and entities integral to the trans-shipment network, signalling targeted enforcement on criminal financial infrastructure.
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Asia-Pacific: On 30 January 2026, Australia’s financial intelligence regulator AUSTRAC released the AML/CTF Starter Programs as part of its educational and compliance support initiative for entities newly captured by Australia’s expanded AML/CTF regime (Tranche 2 sectors). These programs provide structured, regulator-endorsed guidance templates for AML/CTF risk assessments and compliance foundations, easing the transition of legal, real estate, accountancy and other previously unregulated sectors into the formal AML/CTF framework.
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Middle-East & Africa: On 12 January 2026, the Dubai Financial Services Authority (DFSA) implemented a significantly updated regulatory framework for crypto tokens within the Dubai International Financial Centre (DIFC). The updated rules strengthen market integrity and enhance AML/CFT and sanctions-related obligations by clarifying that firms operating in the DIFC must evaluate on a documented, reasoned basis whether each crypto token they engage with meets regulatory suitability criteria.
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Latin America: On 10 January 2026, Colombia’s Dirección de Impuestos y Aduanas Nacionales (DIAN) issued Resolution 000240, a formal tax authority regulation that strengthens reporting obligations for Virtual Asset Service Providers (VASPs) operating in the country. Under the resolution, VASPs are now required to report detailed user transaction data — including cryptocurrency activity and associated user information — to DIAN.
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Key takeaway: January 2026 underscored a global shift from fragmented oversight to more assertive, hands-on regulation across traditional finance, digital assets, and emerging risk areas. Regulators worldwide tightened expectations around governance, transparency, and firm-level accountability — whether through centralised supervision, sharper use of sanctions, clearer onboarding into AML regimes, or deeper scrutiny of crypto activity. The common thread was a stronger emphasis on proactive compliance, with institutions expected not only to follow rules, but to evidence risk-based judgement, data quality, and ongoing monitoring across customers, assets, and transactions.

As regulatory landscapes evolve, RZOLUT leverages AI-first compliance technology to help clients adapt rapidly, reduce compliance costs, and maintain readiness across global jurisdictions.

RZOLUT Empowers Compliance Teams with Data-Driven RegTech Solutions

At RZOLUT, our mission is to empower compliance teams by delivering advanced, data-driven RegTech solutions. We simplify risk management and drive operational efficiency using cutting-edge AI and deep domain expertise. Stay tuned for the latest company news, insights, and stories that inspire!

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Product Spotlight

RZOLUT Monitor

It delivers continuous, event-driven risk intelligence around adverse media. Powered by RZOLUT’s AI-native ContentStream™ engine, it tracks entities over time and triggers alerts only when material risk changes occur — helping organizations move from periodic reviews to proactive, always-on risk surveillance.

Key Features & Benefits

Continuous Monitoring: Always-on tracking
Event-Driven Alerts: Notifications triggered only by meaningful risk shifts, not noise
Reduced Alert Fatigue: Risk-based frameworks minimize false positives
Early Risk Detection: Identify emerging issues before they escalate
Regulatory Defensibility: Time-stamped, source-linked, audit-ready intelligence
Enterprise Scale: Confidently monitor thousands to millions of entities globally

Expert Tip

"Entity resolution goes beyond de-duplication—revealing hidden links, reducing false positives, and sharpening risk decisions."

- Ankush Thakur, Executive Director

News Articles

AUSTRAC backs newly regulated sectors with release of AML/CTF program starter kits

AUSTRAC has released its anti-money laundering program starter kits (kits), designed specifically to help small businesses in newly regulated sectors to meet their compliance obligations and manage ML/TF risks, while also reducing the time and cost of compliance.

Former Google Engineer Found Guilty of Economic Espionage and Theft of Confidential AI Technology

A federal jury in San Francisco convicted former Google software engineer Linwei Ding, also known as Leon Ding, 38, on seven counts of economic espionage and seven counts of theft of trade secrets for stealing thousands of pages of confidential information containing Google’s trade secrets related to artificial intelligence technology for the benefit of the People’s Republic of China (PRC).

Former Sri Lankan Media Ministry Secretary Anusha Palpita Arrested in Corruption Probe

Former Secretary to Sri Lanka’s Ministry of Mass Media and ex-Chairman of the Telecommunications Regulatory Commission of Sri Lanka (TRCSL), Anusha Palpita, was arrested on Tuesday by the Commission to Investigate Allegations of Bribery or Corruption (CIABOC) in connection with an investigation into alleged unexplained wealth.

European Union: EU institutions give businesses the gift of legal certainty on sustainability rules

In February 2025, the European Commission presented its “Omnibus” package aiming to delay application and simplify the CSRD1, the ESRS2, CSDDD3 and the EU Taxonomy with the ultimate goal of reducing administrative burden and thus addressing concerns that the rules would hamper European competitiveness. In parallel, and with an aim to address similar concerns, a proposal for simplification and delay to the EUDR4 moved swiftly through the legislative process.