Source of Funds & AML Compliance

Source of Funds & AML Compliance

Saint Lucia’s Citizenship by Investment Unit (CIU) maintains stringent due diligence standards in line with FATF, OECD, and regional AML guidelines. All applicants—regardless of nationality or investment route—must undergo multi-layered vetting to ensure funds are lawfully sourced and the applicant poses no reputational or national security risk.

Know Your Client (KYC) & AML Documentation Requirements

The required documentation for verifying source and path of funds includes:

  • Bank Reference Letters from a licensed financial institution with at least three years of history with the applicant.
  • Certified Bank Statements showing accumulation and transfer of funds (minimum 12 months, preferably longer).
  • Employment or Business Ownership Evidence, such as audited financials, tax returns, employment contracts, or corporate shareholder registers.
  • Real Estate or Asset Sale Agreements, if capital was generated via liquidation of property or securities.
  • Loan Agreements, where applicable (must be from a regulated lender, and unsecured loans are generally disfavored).
  • Notarized Affidavit of Source of Funds, outlining in narrative form how the funds were generated and transferred.

All documents not in English must be translated by a certified translator and apostilled or legalized based on the applicant’s jurisdiction.

Enhanced Scrutiny: High-Risk Profiles

Applicants falling into “elevated scrutiny” categories face more rigorous reviews. These include:

  • PEPs (Politically Exposed Persons) or individuals with close ties to PEPs.
  • Citizens or residents of sanctioned, blacklisted, or high-risk jurisdictions, including those with known corruption or human rights issues.
  • Applicants with significant crypto-derived wealth, which requires additional documentation such as transaction histories, wallet verification, and fiat conversion pathways.
  • Beneficial Owners of Complex Corporate Structures, especially those involving nominee directors or offshore trusts.



In such cases, the CIU may require third-party forensic reports, and may consult Interpol, regional security agencies, or specialized private intelligence firms before issuing a recommendation for approval.

Transfer Mechanics & Red Flags

All investment funds must be transferred from the personal bank account of the applicant or a qualifying legal entity (e.g., a family trust or holding company, subject to prior approval). Transfers must originate from regulated financial institutions in jurisdictions with adequate AML controls.

Red flags that can delay or derail an application include:

  • Use of intermediaries or shell entities without transparency.
  • Incomplete or inconsistent financial narratives.
  • Discrepancies between declared income and declared net worth.
  • History of denied visa applications or unexplained offshore accounts.



To mitigate such risks, many advisors now conduct internal pre-clearance audits before submission—a recommended best practice for complex profiles.