Source of Funds & AML Compliance

Source of Funds & AML Compliance

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Given growing EU scrutiny of investor migration programs, Greece has substantially strengthened its AML/KYC enforcement regime. The Ministry of Migration and Greek banks now implement multi-layered due diligence on all Golden Visa applicants.

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Documentation Requirements

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Applicants must provide:

  • Detailed bank statements tracing the origin of funds (six to twelve months prior)
  • Tax returns, property sale agreements, or business income proof
  • Certified translations and apostilles for all foreign documents
  • Enhanced documentation for politically exposed persons (PEPs)

Documentation must prove both source of wealth (how funds were accumulated) and source of funds (the specific transfer for investment).

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Fund Transfer Protocols

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Capital must be transferred through:

  • Licensed banking institutions within the EU
  • In the applicant’s own name, not through third parties
  • Typically into a Greek bank account, unless exempted under investment agreements (e.g., direct payment to a developer held in escrow)

Transfers through crypto platforms, cash equivalents, or nominee accounts are disallowed.

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High-Risk Profiles and Rejection Risks

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Extra scrutiny is applied to:

  • Nationals of high-risk jurisdictions (e.g., North Korea, Iran, Russia under sanctions)
  • Crypto-millionaires with limited fiat documentation
  • Applicants with adverse media or political exposure

Applications may be rejected if any red flags emerge, including unexplained wealth, poor documentation, or undeclared international sanctions.

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