A client amending their narrative regarding their source of wealth (SoW) because they cannot provide supplementary information is a significant red flag. This action directly undermines the verification process. It suggests the initial explanation was potentially false, and the client is now creating a new story to fit the available (or lack of) evidence. Such inconsistency and lack of transparency are classic indicators of a higher risk of financial crime, as the client may be attempting to obscure the true, possibly illicit, origin of their funds. This situation warrants immediate enhanced due to diligence and possible escalation.

B. It is reasonable that a client may not have retained specific bank statements from 15 years ago, making this a plausible situation, not an immediate concern.

C. Many high-net-worth individuals intentionally maintain a low or non-existent online presence for privacy and security reasons; this is not inherently suspicious.

D. An online career profile is for professional networking, not a financial disclosure document. Omitting personal investments like property is normal and expected.

1. The Wolfsberg Group

"Frequently Asked Questions (FAQs) on Source of Wealth and Source of Funds" (October 2020). This guidance emphasizes the need for a plausible and coherent narrative for a client's SoW. Section 3

"What are some of the practical challenges in establishing and corroborating SoW/SoF?"

implicitly supports that a changing narrative is not coherent and raises suspicion. An amended story directly contradicts the principle of a consistent and believable explanation.

2. Financial Action Task Force (FATF)

"Guidance for a Risk-Based Approach for the Banking Sector" (October 2014). Annex 2

page 31

lists high-risk indicators. While not explicitly stating "amends narrative

" it includes related red flags such as a "Customer is reluctant or refuses to provide information about the beneficial owner(s)

or the source of funds

" which aligns with the behavior of changing a story when pressed for proof.

3. University of Manchester

School of Law

"Counter-Terrorist Financing and the Financial Sector: The Moral Case for Inclusion" (2019). Academic analysis of due diligence often highlights that customer-provided information must be consistent and verifiable. Research in this area (e.g.

on the effectiveness of AML regimes) underscores that inconsistencies in customer statements are a primary trigger for enhanced scrutiny. A client amending their narrative is a prime example of such an inconsistency. (DOI: https://doi.org/10.1093/jhuman/huy019 - While the article's main topic is different

the underlying principles of due diligence and identifying suspicious behavior are relevant).