Pseudonymising Source-of-Wealth Files for AML QA – UK GDPR-compliant anonymisation per Money Laundering Regulations 2017
Source-of-wealth questionnaires gather biographical and financial history from high-risk or PEP customers to explain the origin of their overall wealth. These documents contain highly sensitive personal data including employment history, inheritance details, and business ownership records. anonym.legal pseudonymises those personal identifiers — preserving the wealth-origin narrative and verification-adequacy context — for compliance quality review.
When this applies
This task applies when source-of-wealth questionnaires and supporting evidence are reviewed by compliance oversight, internal audit, or training facilitators who need to assess procedural adequacy without accessing the specific customer's wealth history and personal biographical data.
How anonym.legal handles it
- Upload the completed source-of-wealth questionnaire and any supporting evidence summaries.
- The engine identifies the customer's name, biographical details, employment history references, named business interests, and any named family members referenced in inheritance or gift explanations.
- Each individual is pseudonymised consistently; wealth-origin category, evidence type, and compliance-officer verification notes are preserved.
- Business entity names referenced as wealth sources are preserved unless you flag them for pseudonymisation.
- A reversible mapping table is produced with UK/EU data residency.
- Release the pseudonymised questionnaire for quality review; restore originals before any regulatory submission.
What you provide
- Completed source-of-wealth questionnaire
- Supporting evidence summary or inventory
- Compliance officer's adequacy assessment notes
Limitations & cautions
- The tool does not assess whether the source-of-wealth evidence provided is sufficient for the risk level of the customer.
- Employment history references that contain employer names are pseudonymised at the individual identifier level; the employer name may be preserved unless flagged.
- The pseudonymised questionnaire is for internal review only; regulatory submissions require the re-identified original.
FAQ
Should I pseudonymise employer names as well as the customer's name?
Employer names are typically corporate identifiers rather than personal data. However, if the employer name would readily identify the individual in context, you can flag it for pseudonymisation before processing.
How are inheritance or gift explanations handled when they name the donor?
Named donors or family members referenced in inheritance or gift explanations are pseudonymised as distinct individuals with consistent pseudonyms throughout the document.
Can a pseudonymised source-of-wealth questionnaire be used in external AML training?
Yes, provided the pseudonymisation is robust enough to prevent re-identification in the training context. For external training, obtain legal advice on the adequacy of pseudonymisation for the specific disclosure context.