Source of wealth mismatch in EU banking
You maintain a bank account with an EU credit institution. The account is active, transactions are lawful, and income continues to flow without apparent issues. During a periodic review, enhanced due diligence, or account change, the bank requests clarification of your source of wealth — not a single transaction, but how your overall financial position was accumulated over time. From your perspective, the explanation is straightforward: income was earned legally, assets were built gradually, and funds currently on the account are legitimate. From the bank's perspective, the issue is not legality, but coherence. When declared income, asset growth, lifestyle indicators, and historical timelines do not align into a single, consistent narrative, a source-of-wealth mismatch arises. As a result, accounts may be restricted, relationships downgraded, or terminated — even where no transaction is suspicious.
Input Data
- Account holder: individual or beneficial owner
- Bank jurisdiction: EU member state
- Review trigger: periodic KYC review or enhanced due diligence
- Declared income: employment, business, dividends, crypto, capital gains
- Observed wealth: balances, assets, lifestyle indicators
- Wealth accumulation period: multi-year or cross-border
- Assumption: lawful income automatically explains wealth
Jurisdiction Conflict
EU bank — source-of-wealth assessment
- Requirement to assess long-term wealth formation
- Focus on plausibility, not single documents
- Low tolerance for unexplained gaps
Client narrative — fragmented accumulation
- Income earned across different countries
- Asset growth over multiple legal regimes
- Partial documentation or informal history
Compliance pressure
- AML rules prioritise consistency over nuance
- Mismatch treated as elevated risk
- Default response is restriction or exit
The conflict is not about a specific transfer. It is about whether the client's overall financial story makes sense as a whole.
AI Analysis
Scenario A — Request escalation
- Repeated demands for historical clarification
- Broad documentation requests
- Risk: review paralysis
Scenario B — Account restriction
- Transaction limits imposed
- Incoming or outgoing funds delayed
- Risk: operational disruption
Scenario C — Relationship termination
- Bank exits the client relationship
- Account closed after review
- Risk: cascading banking loss
Key risk indicators
- Wealth disproportionate to reported income
- Rapid asset growth without documented events
- Cross-border income history
- Crypto or private transactions lacking audit trail
- Lifestyle signals exceeding declared earnings
- Inconsistent explanations over time
Output of Richys AI Analysis
- Reconstruction of wealth accumulation timeline
- Alignment testing between income, assets, and time
- Identification of unexplained value gaps
- Stress testing of bank compliance logic
- Preparation of coherent source-of-wealth narrative
- Flags for expert validation
Expert Boundary
Involvement of a verified EU expert is required for:
- structuring defensible source-of-wealth explanations
- cross-border income and asset reconciliation
- alignment with bank-specific AML expectations
- handling escalated or exit-driven reviews
Case Conclusion
In EU banking, source of wealth is not a formality. It is a holistic plausibility test applied retroactively.
The primary risk lies in assuming that lawful income equals an acceptable explanation. When wealth, timing, and geography do not align into a single narrative, banks default to risk avoidance.
A structured case analysis clarifies where inconsistencies arise, how wealth formation can be coherently presented, and when expert intervention is required before access to banking is reduced or lost.
Start case analysisThis case is for illustration purposes only. Real outcomes depend on residence, income structure, documents and timing. For your specific situation, use structured case analysis with AI and verified EU experts.
Claire Venard
AI assistant – Administrative & Banking