Skip to content
BOL Conferences
Thread Options
#2032091 - 08/06/15 03:30 PM Source of funds for EB-5 Investors
Calmeida12 Offline
100 Club
Joined: Sep 2012
Posts: 249
We have a prospect business customer (EB-5 Regional Center) that wants to open an escrow account with funds from EB-5 Investors, which are foreigners looking to obtain immigrant visas to reside in the US. For CIP purposes, the customer would be the EB-5 Regional Center. The EB-5 investors will not be signers or customers. The US Citizenship and Immigration Services together with the Department of State review and approve the investor based on certain forms that the investor must file as well as providing evidence that capital was obtained through lawful means. How much due diligence is done by the bank on these investors as far as obtaining source of funds and wealth? Thank you.

Return to Top
#2032249 - 08/06/15 08:54 PM Re: Source of funds for EB-5 Investors Calmeida12
MagicCity Offline

Power Poster
Joined: Apr 2003
Posts: 3,003
Fort Lauderdale, Florida
In the interest of giving you a response, I will give my thoughts, but I have not banked this type of customer. I would say that the Regional Center is your customer but to be proactive I would get documentation to support the fact that the State Department reviews and approves the investors.
The deposits would/should identify the foreign investors so I would do a PEP search, Google search etc on them as additional Due Diligence.

Return to Top
#2032292 - 08/07/15 01:03 PM Re: Source of funds for EB-5 Investors Calmeida12
BC78a Offline
Gold Star
Joined: May 2006
Posts: 311
New York
At the prior bank I worked at, we had EB-5 deposits. All we got was a list of the names making up the deposits. When the examiners question this, I explained the program to them and that all parties are vetted by the US Government. In the end this was acceptable. We did however; perform a full CIP on the sponsor.

Just my opinion for what it is worth

Return to Top
#2033262 - 08/12/15 04:31 PM Re: Source of funds for EB-5 Investors Calmeida12
AMLMGR Offline
Junior Member
Joined: Jan 2010
Posts: 35
I agree with the first responder in terms of doing your own due diligence.....I just noticed the SEC indicted a few scams related to EB5 Visas and 'Regional Centers'....You may want to review a few of these for any red flags you can watch for if you choose to bank them.

Return to Top

Moderator:  Andy_Z