IN THIS GUIDE · Reconstructing a multi-account transfer path
Start with the EB-5 eligibility and application overview
Draw the route before collecting statements
List every institution, account owner, currency conversion and intermediary between the original source and the U.S. investment. A closing balance proves where money sits; it does not explain its origin or all earlier movements. Create a dated route with transaction references, then request the records that establish each connection rather than sending a large unindexed bank archive.
Explain third-party movements
Transfers made on the investor’s behalf need clear identification and supporting records. A relative’s account, exchange provider or business account adds a step to explain; it should not disappear from the chronology. Preserve instructions, receipts and the commercial or personal reason for the movement. Counsel can assess whether the arrangement also raises ownership or source-of-funds questions.
Reconcile amounts across currencies
The amount leaving one account may differ from the amount credited elsewhere because of exchange conversion and transaction charges. Keep conversion confirmations and bank fee records beside the corresponding statements. A reconciliation should account for differences rather than treating a near match as sufficient. The qualifying investment must be evaluated in U.S. dollars under the applicable rules.
Protect the record after transfer
Save complete statements and enterprise acknowledgements when the transaction occurs. Online banking history may later become harder to retrieve, especially after an account closes. Retain evidence of administration-fee payments as well as capital. Once the path is documented, keep it connected to the source evidence; a perfect wire trail does not independently prove lawful acquisition.
Keep the source question apart from the path question
Two distinct demands are easily collapsed into one. The path question asks how money travelled from wherever it started to the enterprise, and is answered with statements, wire confirmations and receipts. The source question asks how the investor lawfully came to have it in the first place, and is answered with employment records, tax filings, sale contracts, corporate distributions or similar proof of accumulation. A flawless path across six accounts establishes nothing about lawful source, and a well-documented source is of limited use if the money cannot be followed to the investment. Prepare the two as separate exhibits that meet at a named opening balance. Remember also the requirements the transfer file exists to support: the capital must be placed at risk for the purpose of generating a return, the investment must satisfy the applicable job-creation requirement, and residence obtained through it is generally conditional, with conditions removed only on a later petition.
Anticipate the deposits that will be asked about
Read your own statements as a stranger would. Any credit that is large relative to the account’s normal activity, round in amount, or arriving from a name that appears nowhere else in the file is likely to attract a question, and the time to answer it is while the underlying record still exists. Common examples include a repaid personal loan, proceeds from selling a vehicle, an insurance settlement or a transfer between the investor’s own accounts at different institutions. None of these is inherently problematic; an unexplained one is. Annotate each with its origin and attach the supporting document. Where an account has been closed, request the full history before the institution’s retention period expires, and note that some banks charge for archived statements and take weeks to produce them. Leaving a gap and hoping it passes unnoticed generally costs more than explaining an ordinary transaction.
Sources reviewed 2026-09-07. This guide covers a preparation focus; it is not an individual eligibility assessment.