Source of Funds & AML Compliance

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Both EB-5 and E-2 applicants must prove the lawful source and path of investment funds.

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USCIS and consular officers require:

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• Bank records tracing funds over time
  
• Tax returns
  
• Contracts of sale for property or shares
  
• Inheritance or gift documentation
  
• Business income records
  
  

Funds must originate from the investor’s personal or marital assets and flow through identifiable, legal channels. Transfers via third-party accounts, shell companies, or crypto exchanges face heightened scrutiny.

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Enhanced due diligence applies to:

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• Politically exposed persons (PEPs)
  
• Applicants from sanctioned or high-risk countries (e.g., Iran, Russia, Lebanon)
  
• Crypto-origin wealth
  
  

Investors should expect to provide translated, notarized, and apostilled documents. Legal affidavits and independent accountant letters may be required. Misrepresentation can lead to petition denial and potential bars under INA §212(a)(6)(C).

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