Source of

Wealth and Funds


Compliance with the Fourth AML Directive

on Source of Wealth and Funds in the Remote Gaming Sector

SOWFi is a third‑party White‑Label application which integrates seamlessly with the client’s online platform and branding. SOWFi ensures a disturbless experience for your players by providing a hybrid of soft player real‑time interaction (online), simultaneously coupled with a robust backend expert review that is manually carried out offline.

Through SOWFi, clients can finally assess their players’ source of wealth and funds on a risk‑sensitive basis, as required in terms of the Risk‑Based Approach enshrined in the Fourth AML Directive.

Questionnarie Layout

The risk posed by each player varies in accordance with their geographic, economic and activity profile. An assessment of such risks must necessarily include a review of the player’s financial profile, including their source of wealth and source of funds. The initial step and fundamental approach laid out in the legislation to carry out such an assessment is to ask the player a number of questions to gather information, and where necessary, the documentation required to substantiate the player’s relative declarations.

Four Simple


The four steps are the minimum required
by law to determine the player’s risk level
in terms of source of wealth and funds.

What is your
Are you a
From which
sources have
you obtained
your total
From which
sources have
you obtained
the funds you

Interactive Backend

All recommendations provided by SOWFi reviewers are processed and delivered within a pre-agreed time frame. The system itself provides the client with instant access to each and every request, its status and the recommended outcome on a secure online analysis dashboard. In technical terms, outcomes integrate with the client’s platform through a REST/JSON web service accessible exclusively over HTTPS using message authentication via managed API keys.

This gives the client ongoing visibility of the process and complete control of all outcomes and recommendations.

Integration and Reporting Fees

Fees due for integration are payable 50% in advance and 50% after first year of operation. Volume discounts shall be applied to second bill presented after first year.

For more information about pricing and volume discounts, or to request a meeting, kindly contact us on



Expert Review

Through SOWFi, the client is essenitally plugged into a highly specialized, top notch compliance department. This means that all data and documentation submitted by your end-customer are vetted by a team of specialized personnel trained purposely to monitor such transactions.

Intuitive Reports

All application requests received by SOWFi are vetted, reviewed and assessed on a risk-sensitive basis. The criteria for assessment are pre-agreed with client, and typically based on the client’s player acceptance policy. Various triggers and risk factors, particular to the specific client, are taken into account when establishing the risks posed by the player’s profile, jurisdiction, PEP status and economic activity. The salient variables examined for each request are replicated within each player report and made available to the client for examination and guidance.

SOWFi clients also get access to a wide range of compliance and advisory services aimed at assisting them in achieving compliance with their regulatory obligations. Our team of professionals has extensive knowledge, practical skills, and hands-on experience in helping clients design, implement and refine comprehensive AML/CFT policies, procedures and controls, as well as in establishing an overarching compliance strategy and culture reflecting the latest regulatory and enforcement trends and industry best practices.
Diligex, Mdina Road
Żebbuġ, ZBG 9015, Malta
P: +356 2124 0363
M: +356 7702 1522
Contact us today!