Asked to prove where your money comes from? How source-of-funds checks work

A source-of-funds request is not the same as an ID check

When you open an account, the operator checks who you are: an ID document, proof of address, sometimes a selfie. That is identification and verification. A source-of-funds request comes later and asks a different question: where does the money you are depositing come from? Its wider cousin, a source-of-wealth request, asks how you built up your money in general, for example years of salary, an inheritance, the sale of a property or a business.

Both arrive as the same kind of email, "please upload documents", and often just as you ask for a withdrawal. That is why they feel like a stalling tactic. But an account that passed ID checks months ago can still be asked for source-of-funds evidence. A verified profile does not exempt you; it only means the first layer is done.

Why operators ask: the law and the risk-based approach

In South Africa, a business that makes a licensed gambling activity available is an accountable institution, listed as Item 9 of Schedule 1 of the Financial Intelligence Centre Act. The Financial Intelligence Centre Amendment Act 1 of 2017, published in Government Gazette 40821 on 2 May 2017, added section 21A, which requires an institution to obtain information on "the source of the funds which that prospective client expects to use in concluding transactions". Section 21C adds ongoing due diligence for the life of the relationship. For prominent influential persons, institutions must also take reasonable steps to establish source of wealth as well as source of funds.

The FIC's reference guide for accountable institutions explains the logic. A risk-based approach means controls that are proportionate to the money-laundering risk identified, and the level of verification must match the client's risk profile. Transaction monitoring checks whether your transactions fit what the institution knows about you. The guide also says records of identification are kept for five years after the relationship ends (section 23), so the documents you send do not disappear when you close the account.

The regulator has been blunt about the sector. Its revised gambling-sector risk assessment of 31 January 2024 notes that some clients gambled amounts inconsistent with their occupation or income, and that a high percentage of gambling institutions did not risk-rate clients or enquire about the source of funds. It rated the money-laundering risk linked to clients as high. A source-of-funds request is the industry's answer to exactly that criticism.

What usually triggers a request

Operators do not publish their internal thresholds, and they differ from one business to the next. The patterns below are the ones the FIC lists as possible money-laundering indicators, so they are the patterns most likely to start a review:

• Spending out of line with your profile. Deposits that look large next to the occupation or income you declared at sign-up.
• Deposit, little play, withdraw. The FIC's indicator is buying in large amounts, playing only a small proportion and cashing it all in again.
• Money from or to someone else. Transactions by people other than the account holder, or a customer name that does not match the account name. See payouts to an account in another name.
• The account used as a savings account. Parking money without real play.
• A large win or a sudden rise in stakes. Not suspicious in itself, but it changes your risk profile and often coincides with enhanced checks; see what happens after a big win.
• Status. If you are a prominent influential person or a foreign prominent public official, or closely linked to one, expect source-of-wealth questions as a matter of course.

Checklist: documents to have ready

Operators ask for different things, so read the request first. These are the documents most often accepted, and what each one proves:

Before you upload, tick off the basics:

• Every document is in the account holder's name, the same spelling as the gambling profile.
• No page is missing; a statement with page 2 of 4 removed will usually bounce.
• The period covers what the operator asked for, not just the best-looking month.
• A short covering note explains anything unusual, such as a bonus, a loan repaid by a relative, or a property transfer.

How to clear it quickly

1. Read the request word for word and note the exact documents and period. If it is vague, ask support to name them in writing.
2. Send everything in one upload. Piecemeal answers restart the queue each time.
3. Use the operator's secure upload in the account, not an attachment to a random email address.
4. Keep the ticket number, the date you sent the documents and copies of what you sent.
5. If nothing happens after the time support quoted, follow up on the same ticket and ask what is still outstanding.

For comparison, the UK Gambling Commission's guidance for players says that where a business needs more information for anti-money-laundering checks, it should ask promptly and not only when you request a withdrawal. That is a UK rule, not a South African one, but it is a fair benchmark when you raise a complaint about a request that appeared only at cash-out time.

What not to send, and what not to do

• Never send your online banking password, a one-time PIN, your card's CVV or a photo of the full card front and back unless the operator asks for a masked image.
• Do not edit or crop out transactions on a statement. If there are unrelated lines you would rather not share, ask support first whether blanking them is acceptable. An altered document is treated as a false document, and the FIC lists false documents and refusal among its due-diligence red flags.
• Do not send someone else's payslip or statement to cover your deposits. If a partner funded your play, say so and ask what the operator needs; do not dress it up as your own income.
• Do not try to reshape your deposits to stay under a level you think triggers checks. That pattern is itself a warning sign and can end with the account closed.

If the request makes you realise you are depositing more than you can afford, that is worth acting on before anything else. The South African Responsible Gambling Foundation runs a free helpline on 0800 006 008, and our responsible gambling page lists the tools available.

Licensed bookmaker or offshore casino: what changes

The FIC's sector assessment states the legal position plainly: online gambling is outlawed in South Africa, while online sports betting is legal when it is offered by a licensed South African bookmaker. A provincially licensed bookmaker is an accountable institution under the FIC Act, and if you think it handled your documents unfairly, its provincial gambling board is the place to complain. An offshore casino is outside South African licensing. Its checks follow the rules of wherever it holds a licence, if any, and no South African board will take up your complaint. That weakens your position if a payout is refused after a check, so the cleanest documents you can provide are your best protection. None of this is legal advice; for a large or contested amount, speak to an attorney.