Is this template enough for every source-of-funds review?
No. It is a strong starting structure for one-off reviews, but more complex matters may still require deeper analyst tracing, sanctions exposure analysis, or recurring monitoring support.
RESOURCE
Screening resource
Source-of-Funds Review Template
Structure the facts, questions, and approval logic before a wallet, counterparty, or liquidity source is accepted.
This page is designed for one-off diligence and pre-acceptance review work. It helps teams capture what is known about origin history, counterparty behavior, and escalation triggers before the decision reaches treasury, compliance, or trading approval queues.
What this checklist is for
A practical review template for treasury, compliance, and counterparty-screening teams that need a repeatable way to document source-of-funds findings before settlement or onboarding.
Use this when
A wallet, entity, or liquidity source must be reviewed before onboarding, settlement, or treasury acceptance.
The team needs a repeatable review structure instead of an improvised analyst note or chat thread.
A one-off diligence decision may later need to survive audit, escalation, or executive review.
Frequently asked questions
When should a conditional approval become an escalation instead?
Escalate when the evidence gaps affect the core accept-or-reject decision, when sanctions or high-risk-service exposure is still ambiguous, or when the balance or counterparty carries material operational consequence.
Why does the template separate facts from assumptions so explicitly?
That separation is what keeps the memo usable during audit, internal challenge, or executive review. It protects the team from accidentally treating inference as verified provenance.
Checklist step 01
Define the review target clearly
Record the target wallet, entity name, internal deal or settlement reference, and the business decision the review supports.
State whether the review is for onboarding, treasury acceptance, payout approval, or counterparty clearance.
Note any deadline that changes the urgency of the review or the acceptable level of provisional approval.
Checklist step 02
Capture origin and behavior context
Summarize the source-of-funds path as clearly as the available evidence allows, including major upstream services or venues.
Document any interaction with mixers, high-risk services, sanctions-adjacent routes, or unexplained bridge activity.
Separate verified facts from assumptions or still-open questions so the memo does not overstate confidence.
Checklist step 03
Write the approval logic
State whether the recommendation is clear, conditional, escalated, or blocked.
List the evidence that most strongly supports the recommendation and the gaps that still matter.
Make the rationale readable for treasury, compliance, and executive reviewers who did not perform the original analysis.
Checklist step 04
Prepare for follow-on review
Record who approved the recommendation, who still needs to review it, and what event would trigger reassessment.
Preserve the wallet labels, screenshots, and timeline references used in the memo so later review does not restart from zero.
If the matter may become recurring, identify what should move into watchlist monitoring or deeper diligence scope next.