Money
source-of-fundscompliance
Source of Funds: the #1 cause of EB-5 denial
TL;DR
USCIS requires every dollar of your $800K to trace back to a lawful source. Poor documentation is the most common cause of RFEs and denials.
Source-of-funds (SOF) documentation is the largest single piece of an EB-5 filing — often hundreds of pages. USCIS will trace each layer of fund movement back to its lawful origin. Insufficient tracing triggers a Request for Evidence (RFE), or in worst cases, denial.
- •Trace must cover the entire $800K (not just the latest source)
- •Each source has its own documentation pattern — salary, business sale, inheritance, gift, loan, stock all have distinct requirements
- •Gifts shift the burden to the donor — the donor's SOF must be fully documented
- •Loans must be secured by the investor's own assets (Matter of Hagiwara, 2018)
- •Currency conversion records and bank wires must form an unbroken chain
Plan 6-10 weeks for SOF documentation collection, and longer if multiple sources combine.
How Beyond handles this
Beyond's source-of-funds team has assembled hundreds of files across all common source patterns. We provide tailored document checklists and review drafts before counsel files.
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