For clubs
When your AML process reaches source-of-funds verification, make the evidence easier to get.
Give an identified customer a secure way to support where their funds came from, while giving your compliance team a clearer financial record to review.
Consent-based · Open Banking powered · Human review stays in control
Where VeriSource fits
Your existing systems find the issue. VeriSource helps with the financial evidence.
VeriSource does not monitor gaming machines or identify suspicious players. It enters later in the process.
Your existing systems, gaming records and staff identify something that needs review.
The activity connects to a known customer and your AML process determines what further checks you need.
Your team needs to understand how the customer obtained the money behind the relevant activity.
The customer consents to share relevant banking data so your team can review the financial story behind their explanation.
Your team reviews the evidence and follows your existing AML/CTF process.
That fourth step is the job VeriSource aims to solve.
AUSTRAC guidance specifically says enhanced due diligence may require clubs to identify a customer’s source of funds, seek further information and conduct deeper transaction analysis. AUSTRAC
The problem
The customer has given you an explanation. Now you need to support it with evidence.
Today, that can mean asking for statements, waiting for documents, reviewing transactions, querying deposits and requesting more information.
VeriSource aims to make that part of the process cleaner.
Perhaps the customer says the money came from
- Salary savings
- Business income
- The sale of an asset
- An inheritance
- A loan
- A gift
Your team may then need to understand whether the financial information supports what the customer has told you.
How it works
Ask. Connect. Verify. Record.
Send a secure request when your AML process requires financial evidence from an identified customer.
The customer consents to connect the relevant bank account through Open Banking.
Review financial information that can help support or question the customer’s source-of-funds explanation.
Keep a clearer record of the financial evidence reviewed and any issues requiring further investigation.
Your compliance team makes the decision. VeriSource supports the review.
What the financial evidence can help you understand
Does the story match the money?
Depending on the circumstances, the information may help your team consider:
- Whether regular income supports the explanation
- Whether savings accumulated over time
- Whether a large deposit appeared
- Whether funds came from another person or entity
- Whether transfers moved through several accounts
- Whether significant cash deposits appear
- Whether the transaction history aligns with what the customer told you
- Whether further evidence may be needed
AUSTRAC defines source of funds as how the customer obtained the money, rather than merely which bank account sent it. AUSTRAC
A simple example
What could this look like in practice?
Your AML process identifies an existing, known customer who requires enhanced due diligence. The customer explains that their gaming funds came from savings built through employment income, and your team now needs evidence supporting that explanation.
Without VeriSource
- Request bank statements
- Wait for documents
- Review them manually
- Question unexplained transactions
- Request further evidence
- Record the findings
With the proposed VeriSource workflow
- Send verification request
- Customer consents and connects the relevant account
- Review relevant financial data
- Investigate anything unexplained
- Retain the evidence record
VeriSource doesn’t tell you whether the customer launders money. It helps your team assess whether the available financial evidence supports what the customer told you.
What VeriSource does
- Collect consented financial information
- Support source-of-funds verification
- Review relevant financial activity
- Identify information needing further explanation
- Reduce manual statement handling
- Maintain a clearer evidence record
What VeriSource does not do
- Identify anonymous players
- Detect suspicious gaming activity
- Monitor poker machines
- Monitor TITO activity
- Replace your transaction-monitoring systems
- Replace customer identification
- Replace your AML/CTF program
- Decide whether a customer presents a money laundering risk
- Decide whether to lodge a suspicious matter report
- Guarantee compliance
- Replace your compliance team
Your existing AML systems and people handle those jobs. VeriSource starts when an identified customer needs a source-of-funds verification.
Customer experience
Make a difficult request easier for the customer to complete.
Sometimes your AML obligations require questions customers may not expect. Instead of simply asking “please send us your bank statements”, give the customer a clear request.
The aim: less confusion for the customer and less back-and-forth for your team.
AUSTRAC expressly contemplates clubs asking customers for additional information about their source of funds during enhanced due diligence. AUSTRAC
Explain
- Why you need the information
- What information they will share
- How they provide consent
- What the information will support
- What happens after they submit it
For your compliance team
Give human judgment better evidence.
The final decision always stays with the people responsible for your AML/CTF process. VeriSource aims to organise the financial evidence around the question your team needs to answer.
AUSTRAC expects organisations conducting enhanced due diligence to keep records of the measures taken and their findings. AUSTRAC
A future verification record could include
- Customer details
- Reason for the check
- Consent record
- Accounts reviewed
- Relevant income or deposits
- Source-of-funds evidence
- Items requiring clarification
- Supporting information
- Reviewer notes
- Review outcome
Why Open Banking
Get the relevant financial data without relying entirely on uploaded statements.
Open Banking gives customers a consent-based way to share financial information. For a source-of-funds review, that may help your team see:
- Income
- Deposits
- Transfers
- Account balances
- Transaction history
The data supplies evidence.
Your people supply the judgment.
First-user program
Help shape VeriSource around the way clubs actually work.
VeriSource remains in development. The first club program focuses specifically on the point where a club already has an identified customer, an enhanced due diligence requirement and a source-of-funds question.
The first users can help determine
- What triggers a VeriSource request
- What information customers need to share
- What reviewers actually need to see
- What requires further evidence
- What the final record should contain
- How VeriSource should fit alongside existing AML systems
- How much manual work the process can remove
FAQ
Questions clubs ask.
Does VeriSource find suspicious gamblers?
No. Your existing people, systems and monitoring processes identify activity that needs review.
Can VeriSource identify someone playing anonymously?
No. VeriSource requires an identified customer who can consent to sharing relevant financial information.
When would a club use VeriSource?
When your existing AML process determines that an identified customer requires a source-of-funds check.
Does VeriSource decide whether the money came from crime?
No. It provides financial evidence to support your team’s review.
Does it replace enhanced customer due diligence?
No. It can support the source-of-funds component of that process when source-of-funds verification forms an appropriate part of the customer’s enhanced due diligence.
Does it replace our AML/CTF platform?
No.
Does it submit an SMR?
No. Your club retains responsibility for AML/CTF decisions and reporting.
Why wouldn’t we just ask for bank statements?
You can. VeriSource aims to make the collection and review of relevant financial data more consistent and reduce some of the manual document handling involved.
Can we use VeriSource today?
Not yet. VeriSource remains in development, and the first-user program will help validate the workflow with clubs.
When you need to verify a customer’s source of funds, make the evidence easier to get.
Give customers a clearer way to provide financial evidence and give your compliance team a more consistent process for reviewing it.