Of all the messages a payment provider can send, a source-of-funds request is the one most likely to be read as an accusation. It arrives after the money has landed, asks where that money came from, and often places a restriction on the account until the question is answered.
Let’s review how Blackcat handles these requests.
Blackcat is issued by Papaya, Ltd. Papaya, Ltd. is licensed by the Malta Financial Services Authority as an Electronic Money Institution (EMI). Registration number C55146.
For Blackcat, the source of funds request, like the equivalent request from any EU-licensed provider, is a standard step in a defined process rather than an allegation of wrongdoing. The same documentation principle can also apply when funds arrive after a crypto to fiat exchange.
Understanding what is being asked and the difference between the two versions of the question makes the response far more likely to succeed on the first attempt.
Source of funds and source of wealth ask different questions
These two phrases get used interchangeably, and they should not be. Source of funds asks about a specific sum: this EUR 8,000 arrived on the 14th, where did it come from? Source of wealth asks about the accumulated position behind the account: how did this customer come to have the resources they appear to have?
The distinction matters because the evidence differs completely. A single incoming payment is answered with a document tied to that payment.
An overall financial position is determined by a history of employment, a business, a property sale, an inheritance, and an investment held over the years. Sending a payslip in response to a source-of-wealth question triggers a second request, and sending five years of tax returns in response to a single-transaction question buries the answer.
A worked example. A freelance developer in Tallinn receives EUR 12,000 from a client in Madrid. The invoice answers the source-of-funds question, the signed contract, and the client’s payment confirmation.
If the same account has received similar monthly sums for two years and now holds a substantial balance, a source of wealth question may follow, answered by the business registration, annual accounts, and tax filings.
Why does the question get asked at all
EU anti-money-laundering rules require obliged entities to understand the purpose of a business relationship and to monitor transactions against that understanding.
Where activity does not match the expected profile, the institution is required to establish the background, and enhanced due diligence measures apply in higher-risk situations.
The triggers are mostly mechanical. A sum that is large relative to the account’s history. A first payment from a country the account has never dealt with. A pattern of transfers in and immediately out. A counterparty with no evident connection to the stated purpose of the account.
Fraud data supports the emphasis on transfers specifically: the EBA and ECBfound that the total value of fraudulent credit transfers in the EU/EEA reached EUR 2.5 billion in 2024, and that payment service users bore roughly 85% of credit transfer fraud losses that year, largely through scams in which users were deceived into sending the money themselves.
That last figure explains something about the tone of these requests. A meaningful share of the money moving through European accounts under fraudulent circumstances is moved by the account holder, who is deceived.
A provider checking an unexpectedly large inflow is not only guarding against laundering. It is also checking whether the customer has been recruited, knowingly or not, into moving someone else’s money.
Evidence that satisfies each type of request
| Origin of the money | Evidence usually expected |
| Employment income | Payslips covering the relevant period and an employment contract; the employer name should match the credit |
| Self-employment or business income | Invoice for the specific payment, contract or purchase order, and business registration details |
| Sale of property | Notarial deed or completion statement showing the sale, the amount and the date |
| Sale of a vehicle or valuable item | A sale agreement or receipt identifying the item, the buyer and the price |
| Inheritance or gift | Succession documents, a notarial act, or a signed gift declaration naming the giver and the relationship |
| Investment or dividend proceeds | Statement from the regulated institution showing the disposal or distribution |
| Loan | Loan agreement with the lender identified and the disbursement visible |
Common origins of funds and the documentation typically required to evidence them.
Source: Compiled from EU AML customer due diligence requirements.
A second worked case, showing where submissions go wrong. A retired teacher in Valletta sells a flat and transfers EUR 90,000 into her payment account. She sends a photograph of the estate agent’s brochure, which shows the property and the asking price.
That evidences nothing: it does not name her, does not record a completed sale, and does not tie to the amount received. The notarial deed of sale, which names the parties, the price, and the date, answers the question in a single document.
Three qualities decide whether a submission works. The document must name the amount, or an amount that reconciles to it, with an explanation. It must name the payer, and that name must match what appeared on the credit.
And it must be dated in a way that fits the timeline. Where any of these do not line up, address the gap in your own words in the same submission instead of leaving the reviewer to guess.
Why the account may be restricted while the question is open
A restriction during a source-of-funds review is the part customers find hardest to accept, and it follows from the sequence. The provider has an unexplained inflow and an obligation to establish its origin before the funds move on.
Allowing the money to leave while the question is unresolved would defeat the purpose of asking.
This is also why a partial answer rarely lifts a restriction. The review closes when the origin is established, not when a document arrives. One complete submission that answers the whole question is worth more than three partial ones, and it is worth keeping a copy of everything you send, with dates.
Frequently asked questions
Does a request for funds mean I am suspected of money laundering?
No. It means an inflow did not match the account’s expected profile, and the provider has a legal obligation to establish its origin—the great majority of these reviews close with the funds released once the origin is documented.
Why are my funds frozen while the review is open?
Where the origin of a specific sum is unresolved, a provider will normally restrict its onward movement until the question is answered, because releasing it first would defeat the purpose of the check.
What is the difference between the source of funds and the source of wealth?
The source of funds concerns a specific sum and is verified with a document tied to that payment. Source of wealth concerns your accumulated financial position and is answered with a longer history, such as business accounts or tax filings.
This article explains the sources of funds and sources of wealth requests as they arise under European Union anti-money-laundering requirements. It is general information rather than legal, tax or financial advice, and the documents listed above are indicative rather than exhaustive. What a particular provider accepts and what it is required to obtain in a particular case depend on its own risk assessment and the rules that apply to it. Where a request concerns your own account, follow the instructions in the request itself.