Source of Funds & AML Compliance
Source of Funds & AML Compliance
Given growing EU scrutiny of investor migration programs, Greece has substantially strengthened its AML/KYC enforcement regime. The Ministry of Migration and Greek banks now implement multi-layered due diligence on all Golden Visa applicants.
Documentation Requirements
Applicants must provide:
- Detailed bank statements tracing the origin of funds (six to twelve months prior)
- Tax returns, property sale agreements, or business income proof
- Certified translations and apostilles for all foreign documents
- Enhanced documentation for politically exposed persons (PEPs)
Documentation must prove both source of wealth (how funds were accumulated) and source of funds (the specific transfer for investment).
Fund Transfer Protocols
Capital must be transferred through:
- Licensed banking institutions within the EU
- In the applicant’s own name, not through third parties
- Typically into a Greek bank account, unless exempted under investment agreements (e.g., direct payment to a developer held in escrow)
Transfers through crypto platforms, cash equivalents, or nominee accounts are disallowed.
High-Risk Profiles and Rejection Risks
Extra scrutiny is applied to:
- Nationals of high-risk jurisdictions (e.g., North Korea, Iran, Russia under sanctions)
- Crypto-millionaires with limited fiat documentation
- Applicants with adverse media or political exposure
Applications may be rejected if any red flags emerge, including unexplained wealth, poor documentation, or undeclared international sanctions.
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