Source of Funds & AML Compliance

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Antigua and Barbuda’s Citizenship by Investment Program has significantly tightened its anti-money laundering (AML) protocols since 2023, bringing its regulatory framework in line with the Financial Action Task Force (FATF) and the European Union’s expectations for transparency, traceability, and international cooperation.

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Documentation Requirements

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All applicants must demonstrate the lawful source and verifiable path of their investment funds. This process is not merely formal—it is a core eligibility criterion.

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Key documents required include:

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• Bank reference letters issued by a regulated institution with which the applicant has a minimum of 12 months’ relationship.
  
• Recent personal bank statements (typically 12–24 months), showing accumulation and transfer of funds.
  
• Employment income verification (e.g., payslips, employment contracts) or audited financials for business owners.
  
• Asset sale contracts, if wealth was derived from real estate or securities liquidation.
  
• Tax returns or filings in the applicant’s country of residence.
  
• Affidavit of source of funds, sworn before a notary and accompanied by supporting evidence.
  
  

All documents in a language other than English must be certified and translated by a licensed translator. Documents must often carry apostilles or legalization, depending on their origin country.

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Scrutiny for High-Risk Applicants

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Applicants from jurisdictions deemed high-risk or under FATF monitoring will face enhanced due diligence procedures. This includes:

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• Mandatory interviews conducted via video or in person.
  
• Deep background checks via international databases and watchlists (Interpol, WorldCheck, LexisNexis, etc.).
  
• Scrutiny of politically exposed persons (PEPs), cryptocurrency-derived wealth, and complex offshore structures.

www.harpergreene.com/guides/source-of-funds-aml-compliance-17

For applicants declaring digital assets, the CIU now requires:

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• Wallet histories.
  
• Exchange account statements.
  
• Proof of conversion into fiat through licensed platforms.

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Unexplained wealth, inconsistent declarations, or nominee account structures are red flags and may result in rejection.

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Fund Transfer Procedures

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Investments must be made from an account held in the applicant’s name, in a bank located in a jurisdiction with adequate AML controls. Funds should be transferred directly to:

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• The government-designated escrow account (for donations), or
  
• An escrow account held by the approved real estate or business investment project.
  
  

Use of intermediaries, unregulated financial platforms, or payment from unrelated third-party accounts is strictly prohibited. Applicants are advised to work with a licensed intermediary to oversee this process.

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