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AJAX · EB-5 FIELD GUIDE

How should transfer costs enter the EB-5 budget?

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THE DIRECT ANSWER

Bank charges, currency conversion and document retrieval costs are separate from government filing and professional fees. Confirm what actually reaches the enterprise rather than assuming the gross amount sent equals qualifying invested capital.

Reconcile capital and fee payments

Ask the receiving party to distinguish capital from administration charges in its acknowledgement. Retain lawful-source evidence for money used to pay relevant fees as well. A budget should include possible archive charges and translation work if several countries or banks are involved.

Avoid relying on an exchange-rate assumption until the actual conversion and credited amount can be documented. Separate what leaves the investor’s hands from what reaches the enterprise, and document both. Intermediary bank charges, correspondent fees and the spread applied on conversion can each reduce the credited amount, and a shortfall discovered after the fact is awkward to remedy.

Ask the receiving party in advance what it expects to receive and confirm afterwards what it actually received. Budget separately for the evidence itself: archived bank statements, certified translations, notarization, official copies of tax filings and, where a business is involved, valuation or accounting support. These are preparation costs rather than investment.

Where funds are held or moved through a jurisdiction with exchange controls, allow for the additional documentation those rules require and the time it takes to obtain, since this is frequently the slowest part of an otherwise straightforward file.