Source of Funds & AML Compliance
Antigua and Barbuda’s Citizenship by Investment Program has significantly tightened its anti-money laundering (AML) protocols since 2023, bringing its regulatory framework in line with the Financial Action Task Force (FATF) and the European Union’s expectations for transparency, traceability, and international cooperation.
Documentation Requirements
All applicants must demonstrate the lawful source and verifiable path of their investment funds. This process is not merely formal—it is a core eligibility criterion.
Key documents required include:
- Bank reference letters issued by a regulated institution with which the applicant has a minimum of 12 months’ relationship.
- Recent personal bank statements (typically 12–24 months), showing accumulation and transfer of funds.
- Employment income verification (e.g., payslips, employment contracts) or audited financials for business owners.
- Asset sale contracts, if wealth was derived from real estate or securities liquidation.
- Tax returns or filings in the applicant’s country of residence.
- Affidavit of source of funds, sworn before a notary and accompanied by supporting evidence.
All documents in a language other than English must be certified and translated by a licensed translator. Documents must often carry apostilles or legalization, depending on their origin country.
Scrutiny for High-Risk Applicants
Applicants from jurisdictions deemed high-risk or under FATF monitoring will face enhanced due diligence procedures. This includes:
- Mandatory interviews conducted via video or in person.
- Deep background checks via international databases and watchlists (Interpol, WorldCheck, LexisNexis, etc.).
- Scrutiny of politically exposed persons (PEPs), cryptocurrency-derived wealth, and complex offshore structures.
www.harpergreene.com/guides/source-of-funds-aml-compliance-17
For applicants declaring digital assets, the CIU now requires:
- Wallet histories.
- Exchange account statements.
- Proof of conversion into fiat through licensed platforms.
Unexplained wealth, inconsistent declarations, or nominee account structures are red flags and may result in rejection.
Fund Transfer Procedures
Investments must be made from an account held in the applicant’s name, in a bank located in a jurisdiction with adequate AML controls. Funds should be transferred directly to:
- The government-designated escrow account (for donations), or
- An escrow account held by the approved real estate or business investment project.
Use of intermediaries, unregulated financial platforms, or payment from unrelated third-party accounts is strictly prohibited. Applicants are advised to work with a licensed intermediary to oversee this process.
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