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Source of money requirements

The following are resources that may be helpful in answering your enquiry. Please familiarize yourself with them before moving on.

In brief: You must obtain information about the source of money from the client when providing legal services in respect of a “financial transaction”. Record the information with the applicable date. This comes up in Law Society Rule 3-102(1)(a), Law Society Rule 3-103(4)(b)ii) and Law Society Rule 3-110(1)(a)(ii). The term “money” is widely defined. Read the FAQs about source of money.

Key Resources

Rules - Definitions of “financial transaction” and “money”: Law Society Rule 3-98.

Rules - Source of money requirements:  Law Society Rule 3-102.

Practice Resource - Learn more about source of money requirements: Client ID & Verification - FAQs.

Practice Resource - See New client verification and source of money requirements, Winter 2019 Benchers’ Bulletin (p.13) for an overview of the requirements.

Additional Reading

Practice Resource - Anti-Money Laundering Webinar see in particular 1:41:00.

Practice Resource - Client Identification, Verification and Source of Money Checklist, current to September 1, 2023;  includes Sample Agreement with Agent for Verification. (Note the changes to Law Society Rules 3-102 and 3-104 made on March 8, 2024 that affect parts of this checklist.) 

Practice Resource - See Rule Amendments enhance Law Society’s anti-money laundering measures, Fall 2019 Benchers’ Bulletin (p. 14)

Rules - Exemptions to verification requirements: Law Society Rules 3-99 and 3-101.  

Next Steps

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