Updated

GL-C-05

Glossary · Banks and finance

Capital legalisation

Documentary proof that the money was earned legally (not to be confused with laundering — here everything is transparent and lawful). Needed to open an account abroad and invest in a program. Includes SoW, SoF, statements, declarations, and AML reports.

Full glossary
2 questionshow it was earned and where this money came from
in advancethe only right moment
chainfrom the source to the account

01 / In 30 seconds

The short answer

What it is
Documentary evidence that your capital was earned lawfully
What it includes
A dossier on the source of wealth and of specific funds: SoW, SoF, statements, tax returns
Where it is required
When opening an account, making a programme investment or a major transaction
Not to be confused with
This is not legalising illegal income but evidencing lawful income
The main rule
The dossier is assembled in advance, not in response to a request

02 / In plain words

What Capital legalisation means

Capital legalisation, in our context, is documentary evidence that money was earned lawfully. The term is sometimes confused with money laundering, but the meaning is the exact opposite: this is about transparent capital whose origin you need to be able to show with documents.

The dossier answers two different questions. The first is how your wealth was earned in principle: business, salary, sale of assets, inheritance, investments (source of wealth). The second is where exactly the money for this transaction or investment came from: from which account, from the sale of what, from which receipts (source of funds). One does not substitute for the other — both are usually requested.

The set is made up of documents, not explanations: contracts, statements, tax returns, documents on the sale of assets, business accounts, confirmations of a gift or inheritance. The key requirement is an unbroken chain from the source of income to the account from which the payment is made. A break in the chain is the most common reason for additional requests and refusals.

A case from practice

A client’s capital had been built up over years from several sources, and some of the documents were in archives. We assembled the dossier over several months before filing. The check went through without protracted requests — all the answers were ready in advance.

When it is required

  • Opening an account abroad
  • An investment under a citizenship or residence programme
  • Property purchase
  • A large international transfer
  • Entering private banking
  • A request from the bank’s compliance

03 / What it covers

What the dossier includes

01

Source of wealth

  • The business and its accounts
  • Employment income
  • Sale of assets
02

Source of funds

  • Account statements
  • Specific receipts
  • Movement up to the payment
03

Special cases

  • Inheritance
  • A gift from relatives
  • Investment income
04

Confirmations

  • Tax returns
  • Contracts and certificates
  • Audit reports

04 / How it works

How the dossier is assembled

Step 1

Map out the sources of income

Step 2

Gather supporting documents

Step 3

Build an unbroken chain

Step 4

Close gaps with explanations

Step 5

A dossier ready for filing

05 / Key facts

What you need to know

01

SoW and SoF are different questions; both are needed

02

The larger the sum, the deeper the check

03

The chain must be unbroken

04

Cash and informal income are the hardest to evidence

05

Documents from archives and earlier years are requested in advance

Common mistakes

  • Starting to gather documents after the bank’s request
  • Explaining the source in words instead of documents
  • Leaving gaps in the chain of fund movements
  • Mixing personal and business flows
  • Hiding difficult episodes instead of explaining them

06 / Expert advice

Klara Rihter

How to prepare in advance

Gathering starts before filing and before going to the bank. A map of the sources of income over the relevant period is drawn up, documents are gathered for each, and a chain is built up to the account from which the payment will be made. Gaps — old transactions, income without documents — are closed in advance with certificates, affidavits and indirect evidence.

What we do for you. This is the most important part of the preparation. It is on the source of funds that applications most often stumble. We start work with a review of the sources of capital and assemble the dossier well before filing — because such documents are much harder to obtain after the fact.

Klara RihterBanking compliance and source of funds specialist

07 / Questions

Frequently asked questions

Documentary evidence that your money was earned lawfully. It has nothing to do with money laundering — the meaning is the exact opposite.

Source of wealth explains how your wealth was earned overall. Source of funds explains where exactly the money for this transaction came from. Both are usually requested.

Contracts, statements, tax returns, business accounts, documents on the sale of assets, confirmations of inheritance or a gift.

Gaps are closed with indirect evidence, certificates and affidavits. But such points are explained in advance rather than left to the reviewer’s discretion.

This is the hardest situation. It is dealt with separately and candidly: hiding episodes is pointless, as the check will see the break in the chain anyway.

Before filing and before approaching the bank. Documents from archives and from past counterparties take a long time to obtain.

Author: Klara Rihter

Reviewed by: Sergej Evdokimov

Sources: FATF — on the source of funds

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Anna Kovalevskaya, lead lawyer at BRIDGES GLOBAL
Anna KovalevskayaLead lawyer, citizenship and residency, 12 years of practice