Investment‑migration programs—including citizenship‑by‑investment (CBI), EU golden‑visa schemes, and the U.S. EB‑5 visa—require applicants to prove that the money they intend to invest originates from a lawful source. From July 2027 EU anti‑money‑laundering rules will also obligate banks and agents handling golden‑visa applications to collect detailed source‑of‑funds and source‑of‑wealth information.
Source of funds vs. source of wealth
- Source of funds – the origin and means of transfer of the specific amount being invested.
- Source of wealth – the broader set of activities that generated the applicant’s overall net worth.
The Wolfsberg Group defines source of wealth as the activities that “generated, or significantly contributed to, the customer’s overall net worth,” while source of funds concerns “the origin and means of transfer” of the money itself. Due‑diligence firms verify both, as recommended by the Financial Action Task Force (FATF) in its 2023 report on investment migration.
Legal requirement: lawful origin
All programs test the money for lawful origin:
- U.S. EB‑5 – statute requires investors to show that capital and fees “were obtained from a lawful source and through lawful means.”
- Dominica, Grenada, Saint Lucia – application guides state that funds must be “acquired legally” or “legal.”
- Eastern Caribbean Citizenship by Investment Regulatory Authority (ECCIRA) – regional standards demand “verifiable proof of the lawful source and transfer of funds.”
Typical documentation by money type
| Money source | Common documents required |
|---|---|
| Salary | Employment letter, 12 months of bank statements, notarized affidavit (Dominica). EB‑5 also requires personal tax returns for the past seven years from every filing jurisdiction. |
| Company profits / dividends | Audited financial statements, board resolution approving dividend, bank statement showing receipt, tax declaration. |
| Sale of shares or property | Sale contract; for shares, share certificates or company register extracts showing pre‑ and post‑sale holdings. |
| Inheritance | Solicitor’s letter, will and probate documents, any paperwork evidencing asset transfer from the deceased. |
| Gifts | Affidavit from donor explaining reason for the gift and donor’s source of wealth, certified copy of donor’s ID. U.S. law requires the investor to file the donor’s lawful‑source records. |
| Funds from a third party | Proof of source of funds/wealth for the third party (e.g., employment letter/contract). FATF stresses that the third party must also be vetted. |
| Loans | Allowed in some programs (e.g., EB‑5 after May 14 2022) if the loan is “in good faith” and not used to circumvent lawful‑source rules. Non‑bank lenders must provide their own lawful‑source records. Ireland’s former Immigrant Investor Programme rejected many applications financed with loans. |
| Cryptocurrency | Proof that digital assets were converted into tangible capital (cash) and evidence of lawful acquisition (e.g., business sale, mining revenue). Saint Kitts and Nevis requires a separate non‑crypto wealth proof and imposes extra due‑diligence fees. The U.S. DHS proposed rule (July 2 2026) permits crypto‑derived cash after the same evidentiary standards as traditional funds. |
How the funds must be transferred
- Portugal (Golden Visa) – bank declaration (registered with the Bank of Portugal) confirming the required amount was transferred.
- Greece – payment of property price by crossed bank check or other bank transaction, with buyer and seller declaring details before a notary.
- Dominica – funds must be placed in an irrevocable escrow account with an authorized agent, trust company, or custodial firm.
- EB‑5 – applicant must name every person who transfers money into the United States on their behalf.
- FATF warns that the involvement of a financial institution does not automatically satisfy source‑of‑funds or source‑of‑wealth checks.
Upcoming regulatory changes
- ECCIRA – signed September 2025; national legislation enacted by all five Caribbean states by December 2025; operational in 2026. It will place applicants’ financial documentation in a centralized database and make personal interviews mandatory (Grenada amendment bill, July 2026).
- EU Anti‑Money‑Laundering Regulation – effective July 2027 (Article 41). Banks, agents, and other service providers for residence‑by‑investment applicants must obtain expanded information on both source of funds and source of wealth. The regulation excludes citizenship‑by‑investment schemes, which the EU views as conflicting with Union citizenship status.
Building a compliant file
Due‑diligence teams cross‑check all documents to ensure consistency between declared income, assets, and the money trail. Practical steps:
- Start with the government‑specified checklist (e.g., Malta’s 2020 form, Dominica’s guide).
- Map every transfer from the point the money was earned to the final investment, collecting a supporting document for each step (employment letter → bank statement → transfer receipt).
- Obtain notarized affidavits where required (e.g., gifts, source‑of‑funds statements).
- Verify third‑party sources (relatives, lenders) with the same level of documentation.
- Prepare for on‑chain verification if using cryptocurrency, including wallet control evidence and conversion records.
By assembling a complete, chronological paper trail that satisfies both source‑of‑funds and source‑of‑wealth checks, applicants reduce the risk of rejection across CBI, golden‑visa, and EB‑5 programs.
Source article: www.imidaily.com
