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RURAL MUNICIPALITY OF RITCHOT · EB-5 FIELD GUIDE

Is a wire receipt enough to establish lawful source of funds?

Sources checked:

THE DIRECT ANSWER

No. It documents a transfer but does not alone explain how the investor lawfully obtained the money.

Trace the transaction backward

Provide the relevant source and intermediate transaction records. Avoid treating receipt by the project as proof of the entire source-and-path analysis.

As a continuous chain from the origin of the money to the enterprise, with a document at every step: sale agreements, corporate records, tax filings and bank statements together, rather than a bank balance and a covering letter. Where gifts, loans, inheritances or asset sales are involved, provide their real terms, since a narrative cannot substitute for a transfer or agreement that was never actually documented. The registered mortgage, deed and lender's appraisal can corroborate this secured transaction, but current policy does not make the farmland's entire acquisition history a categorical condition for contributed cash proceeds. A final balance statement does not necessarily explain how funds were earned, owned or transferred, particularly when several transactions connect the original asset to the investment.