Where the money came from and how the person came to have it are two different questions. Cyprus law asks both, of the customer and of the beneficial owner, in exactly one sub-paragraph. Everywhere else it asks less. It defines neither, and the supervisor's evidence table gives them one row.
That division is statutory, not supervisory. Section 61 of L.188(I)/2007 carries the ordinary customer due diligence measures and section 64 the enhanced ones, and a lawyer supervised by the Bar Association and an accountant supervised by ICPAC read the same sections. ICPAC's AML Directive, issued under section 59(4) of that Law and binding on the members it addresses, tells them how to do the work. The operative text of the Law is Greek, no official English version exists, and the renderings here are ours.
The sub-paragraph is section 64(1)(a)(iii). For business relationships or transactions with high-risk third countries, one of six enhanced measures the Law lists is the collection of information on the origin of the funds and the source of the wealth of the customer and of the beneficial owner. Both questions, both people, one line. The Greek word for wealth appears exactly once in the whole of L.188(I)/2007, and that line is where.
A politically exposed person gets a different sentence. Under section 64(1)(c)(ii)(bb) the obliged entity takes adequate measures to ascertain the source of the assets and the origin of the funds which concern a business relationship or transaction with such a person. Two things moved. The noun is assets, not wealth. And both limbs are tied to what the relationship or the transaction involves, rather than to everything the person has.
In ordinary due diligence the money question is conditional. Section 61(1)(d) requires continuous oversight of the business relationship, with close examination of the transactions carried out during it, to ensure they are consistent with the data and information the obliged entity holds about the customer, the business, the customer's risk profile and, where required, about the origin of the sums of money. Where required, which is not the same as always.
Count the vocabulary across those three provisions. Two words for the question: origin, and source. Four for the thing asked about: the sums of money in section 61, the funds and the wealth in the high-risk-country limb, the assets and the funds again in the PEP limb. Each is a separate Greek noun and the Law defines none of them. Section 2 does define property, as assets of every kind, corporeal or incorporeal, and it never defines wealth, funds, source or origin.
Section 64 holds one more origin, and that one is not about a person at all. Where a crypto-asset service provider handles a transfer to or from a self-hosted address, it applies mitigating measures proportionate to the identified risks, which include one or more of four; one of the four is requiring additional data on the origin and the destination of the crypto-assets transferred.
The international standard sorts the same two phrases the other way round. FATF's assessment methodology, whose criteria are addressed to countries and assessors rather than to firms, uses the phrase source of wealth exactly once, at criterion 12.1(c): financial institutions should be required to take reasonable measures to establish the source of wealth and the source of funds of customers and beneficial owners identified as PEPs. Criterion 22.3 is what carries that recommendation to the businesses and professions criterion 22.1 lists, accountants, lawyers and trust and company service providers among them, in the situations it sets out. The only other criterion using source of funds is 10.7(a), ongoing due diligence, and it too is conditional: including where necessary, the source of funds. So the standard attaches wealth to the PEP, while the Cyprus text attaches wealth to the high-risk third country and asks the PEP about assets. That is an observation about two texts on the same desk, not a defect in either. FATF's glossary defines funds, property and reasonable measures. It defines neither of the two phrases.
Which is where the supervisor earns its place, because the supervisor is where the documents are. ICPAC's Directive makes establishing and corroborating the size and source of wealth one of eight measures its enhanced due diligence list must include, and that item names wealth without naming funds. For a PEP-related client it says the firm should apply specific measures, among them taking adequate measures to establish the size and source of wealth and funds of clients. Size is the supervisor's word: the Law asks where it came from and never how much there is. Annex III then prints a suggested non-exhaustive list of evidence in which source and size of wealth and funds is a single row, marked where applicable, answered by a CV and/or a memo prepared by the person in charge from a public search of credible websites and public registers and/or appropriate supporting documentation, the examples given for that last item being an estate copy for inheritance, court decisions for divorce settlements, sale contracts for property or investment sales, and a latest payslip or employment contract for employment. Then the row points members somewhere else again, to a separate ICPAC guidance on establishing source of funds and source of wealth. That guidance is neither the Directive nor the Law.
One row, two questions. A payslip answers where the money came from. Filed against how the person came to have it, it answers a question nobody asked.
Not legal advice. Verify against the primary source before acting.
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