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Eligibility & Due Diligence

Source of Funds vs Source of Wealth: What Grenada CBI Expects

Source of funds and source of wealth for Grenada citizenship by investment: the difference, the evidence that works and the gaps that trigger questions.

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Most delays in Grenada citizenship by investment files come back to one subject: money that cannot be explained well enough. Applicants often arrive with a strong bank statement and assume the job is done. Due diligence teams see a balance and ask where it came from, how it got there, and whether the person in front of them could plausibly have earned it.

Two terms sit at the centre of this. Source of funds is the origin of the specific money you will use for the investment and fees. Source of wealth is the story of how you accumulated your total net worth over your working life. Grenada's Investment Migration Agency looks at both, and a file that proves one without the other tends to attract a request for further information.

Below is how the two differ in practice, what evidence tends to work for common types of wealth, and the mistakes that cost applicants months. Exact documentary requirements are set by the IMA and your agent; use this as a framework for the conversation.

The difference, with an example

Imagine an applicant who plans to pay the National Transformation Fund contribution from a savings account holding the proceeds of an apartment sale. The source of funds evidence is narrow and transactional: the sale agreement, the completion statement, the bank statement showing the proceeds arriving, and statements showing the money sitting in that account until it is sent to Grenada.

The source of wealth question is broader. How did this person come to own the apartment in the first place? If it was bought twenty years ago with salary savings and a mortgage, the answer is employment records, the original purchase deed and mortgage statements. If the applicant also owns two companies and a share portfolio, investigators want a rough picture of how those were built too, because total wealth must make sense against the career described.

Neither question requires proof of every transaction in a lifetime. What is needed is a coherent, documented narrative in which the big steps are supported by records and nothing material is left unexplained.

Evidence that typically supports common types of wealth

The right documents depend on how the money was made. As a starting point, agents commonly ask for the following, with certified translations where needed:

  • Employment income: employment contracts, payslips or salary certificates, several years of tax returns, and an employer letter confirming role and pay.
  • Business ownership: company registration and shareholding records, audited or filed accounts, dividend resolutions and the tax paid on distributions.
  • Sale of a business or shares: the sale and purchase agreement, completion documents, proof of payment received and the tax treatment.
  • Property sale: the original purchase deed, the sale contract, the completion or settlement statement and bank receipt of proceeds.
  • Inheritance: the will or probate grant, estate accounts, the deceased's death certificate and evidence of transfer to you.
  • Investment returns: brokerage statements over several years and records of the original capital invested.
  • Gifts: a signed gift declaration, proof of relationship, the donor's own source of wealth, and the bank transfer.

Where explanations break down

Cash. Wealth built in cash-heavy businesses is lawful in many places but hard to trace. Deposits with no paperwork behind them are one of the most common triggers for further questions. Business records, tax filings and banking history over time help.

Round-tripping between companies. Money that passes through several related companies, sometimes in different countries, before landing in a personal account looks like layering even when the reasons are ordinary. Map the flow on paper first.

Recent large transfers. A large sum that arrived weeks before the application, from a relative or a company, needs a clear reason and supporting documents. Unexplained timing invites questions.

Income that does not match taxes. If declared income in tax returns is far below the wealth claimed, investigators will ask why. The answer may be legitimate, such as capital gains taxed differently, but it must be explained.

Lifestyle mismatch. A modest salary history combined with multiple properties and a yacht needs another source, such as inheritance or a business, documented properly.

Building a source-of-wealth narrative that holds up

Agents and their compliance teams usually help prepare a short written statement backed by an index of documents. A workable approach:

  1. Write a chronological summary of your working life: education, jobs, businesses founded or bought, major asset sales and inheritances.
  2. Attach an approximate figure to each major source and check that the total is broadly consistent with your declared net worth.
  3. For each major event, list the document that proves it and obtain certified copies or official extracts.
  4. Trace the investment money specifically: from its origin, through each account it has passed through, to the account that will pay Grenada.
  5. Flag anything unusual yourself, such as a period of cash trading or a loan from a relative, with a brief explanation and whatever evidence exists.
  6. Have the agent review the narrative for gaps before the application is lodged, not after a request for information arrives.

Paying the investment: keep the route clean

How the money reaches Grenada matters as much as where it came from. The NTF contribution or the real estate purchase price should ideally be paid from an account in the applicant's own name, or from the account already identified in the source-of-funds evidence. Payments from unrelated third parties, from corporate accounts not explained in the file, or split across many transfers raise questions late in the process, sometimes after approval in principle.

If a company will pay, the file should show that the applicant owns or controls it and that the payment is a properly authorised distribution or loan. If a family member will pay, the gift arrangements should be set out before filing.

Banks along the route carry out their own anti-money-laundering checks, so expect your own bank to ask about a large international transfer. Having the same documentation ready avoids frozen payments at the worst possible moment.

Practical habits that save time

Start early. Tax transcripts, probate documents and certified company extracts can take weeks to obtain, especially from abroad.

Keep the figures consistent. Use the same numbers for income and assets across the forms, the CV, the narrative and the bank reference.

Do not over-polish. A frank explanation of a messy period reads better than a smooth story that investigators can puncture.

Keep originals available. The IMA can ask to see further evidence at any point, including after approval in principle.

Mind the exchange rates. Wealth earned in several currencies is easier to follow if the narrative states each figure in its original currency and in US dollars, with the approximate rate and date used.

Use one point of contact. Let the agent coordinate requests to accountants, banks and lawyers so that the same facts are not described in three different ways by three different advisers.

A note on bank references and banking letters

Grenada's programme, like the others in the region, asks for evidence of your banking relationships, commonly in the form of a bank reference letter confirming how long you have held accounts and that they have been conducted satisfactorily. A reference is not source-of-funds evidence in itself: it says you are a customer in good standing, not where the money came from.

Banks in some countries are slow to issue such letters or use formats that do not match what the programme expects, so ask your agent for a template early and allow time for the bank's own compliance review. Where an applicant has recently moved banks, a reference from the previous bank may be needed as well.

Statements should cover the period that matters for the investment funds, show the account holder's name and be certified where required. Screenshots from online banking are rarely enough; ask the bank for official, stamped or digitally verified statements.

Frequently asked questions

Can you use borrowed money for Grenada citizenship by investment?

Borrowing is not automatically excluded, but it needs care. Investigators will ask who the lender is, the terms, and how the loan will be repaid, and the repayment capacity must be documented. Discuss any financing with your agent before arranging it.

Can a parent pay the investment for an adult child?

Usually yes, as a documented gift. The file then needs a gift declaration, proof of relationship and the parent's own source of wealth, because the money is effectively theirs. Plan this before filing rather than adding it later.

Is cryptocurrency accepted as a source of wealth?

Crypto gains can form part of a source-of-wealth story, but the evidence burden is heavy: exchange records, wallet histories, the original purchase funds and conversion to fiat through regulated channels. Confirm current acceptance with your agent first.

How many years of records are needed?

There is no single rule. Source-of-funds evidence covers the specific money, while source-of-wealth evidence may reach back through your career. Several years of tax returns and bank statements are commonly requested as a baseline.

What happens if your source of funds is not accepted?

Usually the IMA asks for more information first. If the explanation remains unconvincing, the application can be refused, and due diligence fees are generally kept. Fixing gaps before filing is far cheaper than answering questions afterwards.

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