Source of Funds & AML Compliance

Source of Funds & AML Compliance

St. Kitts & Nevis has implemented one of the most rigorous AML (Anti-Money Laundering) compliance protocols in the investment migration industry, in response to FATF recommendations and diplomatic pressures from the EU and U.S. Applicants must demonstrate, with a high standard of proof, that their investment funds originate from lawful, traceable, and transparent sources.

KYC and Due Diligence Documentation

Each applicant, including all dependents over 16 years of age, must provide a robust documentation set, which includes:

  • A bank reference letter issued within the last six months from a licensed institution.
  • Personal bank statements covering at least the past 12–24 months, showing fund accumulation and transfer trajectory.
  • Proof of income or business ownership, such as tax returns, audited financial statements, payslips, and employment contracts.
  • Asset sale agreements, where the source of funds derives from real estate, securities, or business disposals.
  • Sworn affidavit of source of wealth and funds, detailing how capital was generated.
  • Certified and translated copies of any document not originally in English, plus apostilles where required.

Applicants from civil law countries should ensure notarial certifications meet common law evidentiary standards accepted in St. Kitts.

Scrutiny of High-Risk Profiles

St. Kitts applies enhanced due diligence (EDD) to applicants who:

  • Are nationals of, or have significant connections to, sanctioned or high-risk jurisdictions.
  • Are politically exposed persons (PEPs) or close relatives of such individuals.
  • Have significant holdings in cryptocurrency or digital assets, especially when source of funds depends on on-chain transactions.
  • Use layered or offshore structures that obfuscate beneficial ownership.

EDD includes third-party forensic background checks, direct communication with foreign authorities, and in some cases, in-person or video interviews conducted by CIU staff or licensed agents.

Fund Transfer Regulations

Investments must be made from the applicant’s personal bank account or a licensed financial entity clearly linked to the UBO. Payments made:

  • From unrelated third parties,
  • From unregulated crypto platforms, or
  • Through correspondent banks in high-risk jurisdictions

will not be accepted and may result in application refusal. The CIU enforces a strict chain-of-custody policy on capital inflows, which must be supported by SWIFT confirmations and escrow agreements when applicable.

A growing number of applicants now engage external compliance specialists to prepare enhanced SOW/SOF dossiers before submission—an advisable best practice for complex profiles.