Money
source-of-fundscomplianceprocess

EB-5 Source of Funds Documentation Checklist

TL;DR

USCIS requires a documented chain showing every dollar of the $800K traces to a lawful origin. The documentation set varies by source type (salary, business sale, inheritance, property, loan, gift, stocks) — but the rule is universal: paper-trail everything, in English, with certified translations where needed.

Source-of-funds (SOF) is the single largest piece of an EB-5 filing — often 200-500 pages. USCIS reviews both the **lawful origin** (where the money came from) and the **path of funds** (how it moved from the origin into the investor's hands and ultimately to the project escrow). RFEs almost always trace to an incomplete chain.

  • Salary / Wages — 5+ years of employment letters, pay stubs, tax returns (matching the salary claim), bank statements showing salary deposits, savings accumulation timeline.
  • Business Sale — sale agreement, buyer's identity, professional valuation, tax returns showing capital-gains reporting, bank records showing sale-proceeds deposit and use of the funds.
  • Inheritance / Gift — death certificate (inheritance) or gift letter (gift), affidavit from the giver, the giver's own SOF (because USCIS recursively traces gifted funds back to their lawful origin too), bank records.
  • Property Sale — title/deed history, professional valuation, sale agreement, registry records, tax records, bank records.
  • Loan / Mortgage — loan agreement (must NOT have the investor's primary residence outside the US as collateral if from a foreign lender), repayment schedule, the lender's own SOF if it's a personal loan.
  • Stocks / Investment Returns — brokerage statements, purchase records, sale records, tax records, capital-gains reporting.
  • Cryptocurrency — exchange statements, wallet histories with on-chain proof, fiat-conversion records, KYC documentation from exchanges, tax reporting.
  • Translation requirement — every non-English document needs a certified English translation. Foreign tax returns and bank statements are the most common volume.

Plan SOF documentation 3-6 months before filing — sourcing certified translations and old bank statements from foreign institutions is slower than people expect, and gaps trigger RFEs.

How Beyond handles this

Beyond coordinates SOF documentation alongside an EB-5 immigration attorney who has filed hundreds of I-526E petitions. We flag the RFE patterns specific to each source type — particularly the 2026 RFE trends around crypto, gift-chain documentation, and salary-accumulation timing.

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