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APPLICATION ANSWERS · EB-5 FIELD GUIDE

Must proceeds pass through my personal account before the investment?

Sources checked:

THE DIRECT ANSWER

Do not assume a universal personal-account routing rule. The file must establish lawful source, the applicant’s rights and the actual payment path under the arrangement used.

Explain an authorized direct payment accurately

If a trust account or other party would send funds directly, obtain the authority, settlement records, recipient instructions and transfer evidence. Identify whose funds are being used and any restrictions. A direct payment is not automatically qualifying, but a personal-account detour does not by itself resolve missing ownership or source evidence either.

Map every account holder, intermediary, instruction, settlement event, and recipient. Hypothetical example: a wind-turbine maintenance entrepreneur sends closing proceeds from a lawyer’s trust account into investment escrow. The retainer, authority, closing statement, wire record, and escrow receipt explain the path together. Assemble commercial closing evidence before writing an immigration narrative. A direct wire may be legitimate, but it still needs proof of ownership, authority, lawful source, investment risk, and the case’s job-creation framework. Do not treat an optimistic business explanation, a later-created letter, or a family arrangement as proof of a missing eligibility fact. Retain bank statements showing both sides of every movement.