Citizenship by investment (CBI) programs and the US EB-5 visa ask you to prove where your investment money came from. From July 2027, European Union law also obliges the banks and agents that serve golden visa applicants to ask.
Almost any lawful money qualifies. The difficulty is the paper trail, which can reach back “decades,” according to IMI’s review of five common reasons CBI applications face rejection.
Source of funds and source of wealth are two separate checks
Source of funds is the origin of the specific money you send to the program. A source of wealth check looks wider, at how you built your whole net worth.
Banking guidance from the Wolfsberg Group defines source of wealth as the activities that “generated, or significantly contributed to, the customer’s overall net worth.” Its definition of source of funds covers “the origin and means of transfer” of the money itself.
Malta used the same split on the form for its 2020 citizenship program. Source of funds was “the activity, event, business, occupation, employment or other source of income from which the funds have been generated.”
The same form described source of wealth as “a summary of the activities and transactions which have generated your total net worth.”
The Court of Justice of the European Union ruled against that Maltese program in April 2025. Malta now grants citizenship through a discretionary route based on merit.
Due diligence firms check both. The Financial Action Task Force (FATF) explains why in its 2023 report on investment migration, which IMI analyzed at the time.
A criminal can use clean money for the investment itself. The report says a source of wealth check helps catch that person moving “wider criminally obtained wealth” once the new status is granted.
The legal test is lawful origin
The texts that govern these programs test the money for lawful origin.
The US statute behind EB-5 is headed “Source of funds.” It requires that investors show the capital and the fees they pay “were obtained from a lawful source and through lawful means.”
Dominica’s application guide asks that applicants “be able to verify that these funds were acquired legally.” In Grenada, the application guide states that “The source of these funds must be legal.”
In Saint Lucia, Regulation 3 of the CBI regulations has the Board appoint people to verify “an applicant’s financial resources and source of funds.”
The five Caribbean CBI states have also agreed on one regional standard. Their agreement creating the Eastern Caribbean Citizenship by Investment Regulatory Authority (ECCIRA) says the regional standards for applicants shall include “financial statements and verifiable proof of the lawful source and transfer of funds.”
The documents each type of money needs
Each source of money leaves its own trail. Malta’s 2020 form listed documents for each one, and several of them appear on other programs’ checklists.
Salary
An employment letter and bank statements prove it. Dominica’s checklist asks for a letter of employment or financial statements, 12 months of bank statements, and a notarized affidavit of source of funds.
For EB-5, you file personal tax returns from the past seven years with every country where you filed them.
Company profits and dividends
Malta’s form listed audited financial statements, the board letter approving the dividend, the bank statement showing it, and the tax declaration that reports it.
A specialist in Turkey’s citizenship program, quoted in IMI’s rejection review, said business owners “struggle to provide the granular documentation governments expect, especially when wealth accumulated through reinvested profits rather than salary payments.”
Sale of shares or property
The sale contract is the core document. For shares, Malta’s form also listed share certificates or company registers that show the shareholding before and after the sale.
Inheritance
Malta’s form listed a letter from a solicitor, the will and probate, and any paper that shows the assets passing from the deceased person.
Gifts
A gift adds a second person to the trail. Malta’s form listed an affidavit from the donor explaining “the reason for the gift and his/her source of wealth,” with a certified copy of the donor’s ID.
Under US law, investors who use gifted money must file the lawful-source records “from the donor.”
Governments look hard at money that moves between relatives. IMI’s rejection review notes that they demand “evidence that gifts represent genuine transfers rather than disguised arrangements.”
Money sent by someone else
Antigua and Barbuda’s investment confirmation form covers the case where a third party sends the funds. It asks for “Proof of source of funds/wealth (eg. Employment letter/contract)” from that person.
FATF’s report says that where the money comes from a relative or associate, “it is important that they are also subject to vetting.”
Loans are allowed in some programs, on conditions
EB-5 accepts borrowed money by statute. For petitions filed on or after May 14, 2022, gifted and borrowed funds count if they were given “in good faith.”
They also must not have been “gifted or loaned to circumvent” the lawful-source rules. When the lender is not a bank, you file the lender’s own lawful-source records.
Ireland treated loans as a reason to refuse. Before it closed its program, it rejected dozens of Immigrant Investor Program applications after it found the investments were financed with loans.
The government stopped accepting applications to the program in February 2023.
In the Caribbean, IMI reported that governments have warned that unauthorized financing arrangements “automatically disqualify applications.” Those arrangements let applicants pay a fraction of the required minimum up front.
The ECCIRA agreement also requires that due diligence include “verification of remittance of investment funds through a licensed financial institution” that has checked the applicant.
Crypto can be a source of funds
Saint Kitts and Nevis accepts cryptocurrency as a partial source of wealth. Its Citizenship by Investment Unit asks for “a separate proof of wealth not derived from crypto” and charges additional due diligence fees.
The US Department of Homeland Security (DHS) published a proposed EB-5 rule on July 2, 2026. Its preamble says digital assets may not be invested directly as capital.
Using them as “a source of tangible capital (e.g. cash)” may be permissible, the preamble adds. It states that “DHS has a practice of permitting digital assets as a valid source of funding” and applies the same evidence tests to them.
The comment period on the proposed rule ended on August 31, 2026.
Alex Recouso, CEO of CitizenX, believes that “the real question is how the applicant lawfully acquired the funds.” He notes that saying “Bitcoin is my source of funds” is “like saying ‘US dollars are my source of funds.'”
In either case, he argues, the answer is “the activity or event behind the wealth: a business sale, salary, investment gains, mining, or something else.”
Recouso accepts that digital assets “can require extra explanation because reviewers are less familiar with them.” He also sees an advantage, because “the movement of funds can be independently verified on-chain, and an applicant can demonstrate control of a wallet.”
Recouso notes that you need evidence of “how the assets were lawfully acquired, just as you would with funds in a bank.” With that evidence, he does not think crypto “should be treated as inherently less credible.”
How the money reaches the program
The transfer itself is the last link in the trail, and programs set rules for it.
Portugal’s immigration agency, AIMA, asks golden visa applicants for a declaration from a bank registered with the Bank of Portugal. The declaration confirms that the required amount was transferred.
Greek law requires that the property price be paid by crossed bank check or another bank transaction. The buyer and seller declare the payment details before the notary, who records them in the deed.
Dominica considers an application after “all monies have been placed in an irrevocable escrow account” with an authorized agent, a registered trust company, or a custodial firm.
For EB-5, you name every person who transfers money into the United States on your behalf.
FATF warns that immigration officials sometimes “assume that the involvement of a financial institution means that source of funds or source of wealth checks will be conducted by the financial institution.”
What changes next
The five Caribbean heads of government signed the ECCIRA agreement in September 2025.
By December 2025 all five had made it national law, the Eastern Caribbean Central Bank said. It added that ECCIRA “is expected to become operational in 2026.”
Grenada’s amendment bill, which the Senate debated in July 2026, would make a personal interview a mandatory part of due diligence. It would also place each applicant’s “financial and source of funds documentation” on the Eastern Caribbean Citizenship by Investment Database.
In Europe, the new Anti-Money Laundering Regulation applies from July 2027. Under Article 41, banks, agents, and other firms that serve residence by investment applicants must obtain more information on their source of funds and source of wealth.
IMI covered what that regulation means for investment migration firms when it was adopted. It excludes citizenship by investment, which it says undermines “the fundamental status of Union citizenship.”
Building your file
Due diligence teams compare your documents against each other. One firm’s chief executive, quoted in IMI’s look at how due diligence works, said his team checks “bank statements, employment letters, et,c to ensure the figures match the declared income or assets.”
Start from the government account and work back to the day you earned the money. Each transfer on that path needs a document.
