# Appendix F — Source-of-Funds Checklist This appendix is the working form of Chapter 15. It introduces no requirement that the chapter does not establish, and every line carries the section it derives from, so that any item can be traced back to the body of the report and to the instrument behind it. It is arranged as the file is assembled: the distinction the examination rests on (A), the evidence expected for each common wealth type (B), the trail of the specific investment funds (C), screening (D), the consistency checks that most often decide a file (E), and the circumstances in which the professional answer is to defer or not to file (F). Two things should be held together while using it, as §15.1 and §15.2 hold them together. The standards are demanding because the sector has been abused — the FATF and OECD joint report of November 2023 records frauds and laundering "reaching into the billions of dollars" (§15.1) — and the same report records that these programmes "attract an array of clients, many of whom have gained their assets legitimately and have benign intentions" (Chapter 15, opening). Most applicants meet the standards without difficulty; what defeats an otherwise sound file is disorganisation, inconsistency and late assembly, not the level of the bar. The appendix is general information and not legal, tax or immigration advice; where the chapters qualify a point as requiring confirmation at the date of application, that qualification is carried here and travels with the item wherever it is used. --- ## A. Source of wealth and source of investment funds The two are distinct and both are examined. The distinction is FATF's, drawn in its June 2013 guidance on politically exposed persons and applied generally in practice; Regulation (EU) 2024/1624, Art. 41 (read with Art. 34(4)) embeds it in EU law for residence-by-investment applicants from 10 July 2027. | Concept | What it is | What the file must therefore contain | Section | |---|---|---|---| | Source of wealth | "The origin of the … entire body of wealth (i.e., total assets)" — an account of how the client's overall position was built | A dated narrative of accumulation across the years in which it occurred, evidenced by the packs at B1–B7; sufficient in itself, independently of any borrowing | §15.2 | | Source of investment funds | "The origin of the particular funds or other assets which are the subject of the business relationship" — the path of the specific money | The specific monies funding the structure traced from an identified wealth event, through named accounts, to the paying account, and then through the statutory payment channels of each component (C) | §15.2, §15.1 | | Both, for contributing family members | The same two questions asked of any person whose money enters the structure | The contributor's identity and relationship, and that person's own wealth and funds evidenced to the applicant's standard | §15.2, §15.8, Ch. 16 | Table F.1 — the two examinations. Assumptions: the reference structure of Chapter 10, in which the funds requirement is approximately €340,000 and upwards in the single-applicant case; quoted definitions are FATF's PEP guidance (June 2013, ¶¶87–88) as applied generally in practice per §15.2. Derived from §15.1, §15.2, §15.8. A file that traces the purchase price impeccably but cannot account for the overall position fails, and so does the reverse (§15.2). **Why both, and why first.** Examining source of wealth in addition to source of funds identifies cases in which legitimate funds are used for the application while the wider wealth is criminal in origin (§15.2). Preparation precedes commitment because the costs of late failure are asymmetric: the citizenship component's US$5,000 due-diligence and processing fee is non-refundable once the application is submitted and the process lapses if the Public Prosecutor's clearance is refused, while on the residence side the qualifying property is acquired in full before the application is made (§15.1, §14.7, §17.10–§17.11). --- ## B. Evidence by wealth type Each pack below is the list set out in the corresponding section of Chapter 15. The packs are typical, not statutory: no per-wealth-type documentary schedule exists in either component, and the lists are professional practice consistent with FATF Recommendation 10, the joint report's due-diligence recommendations and Regulation (EU) 2024/1624, Art. 34(4). The documentary formalities that apply to everything in this section — official form in Portuguese or English, criminal-record certificates issued within the previous three months, certified translations, Hague Apostille or consular authentication (Decreto-Lei n.º 07/2025, Art. 10 and Anexo III) — are at E and §15.12. ### B1. Business ownership and sale (§15.3) | # | Item | Evidence expected | Corroboration | Section | |---|---|---|---|---| | 1 | Ownership and its history | Corporate registration and shareholding records from the official registry of each relevant jurisdiction, covering changes in ownership | Registries checked directly by the examiner, not accepted from the file | §15.3, §15.12 | | 2 | Trading performance | Financial statements for the years in which the relevant wealth accumulated, audited where the jurisdiction requires audit | Reconciliation with item 3 | §15.3 | | 3 | Tax position | Personal and corporate tax filings reconciling with declared profits and distributions | The tax-filing consistency test at E1 | §15.3, §15.13 | | 4 | Extractions | Board or shareholder resolutions and distribution records behind each significant dividend or drawing | Bank credits matching each resolution | §15.3 | | 5 | Disposal, where the wealth event is a sale | Sale-and-purchase agreement, completion statement and the bank credit of the proceeds | Counterparty and corporate-history screening | §15.3, §15.11 | | 6 | Route to the paying account | Bank statements tracing the accumulated funds to the accounts that will fund the structure | The trail at C | §15.3, §15.2 | Table F.2 — business-owner pack. Assumptions: private (not listed) business; examiners verify rather than accept, and adverse-media searches are run in the languages of the jurisdictions of origin and of association (§15.3, §15.11). Derived from §15.3. Informal or cash-intensive sectors, inaccessible registries and records lost across decades are practical difficulties, not automatic disqualifications; reconstruction through independent accountants and historical banking records takes months rather than days and is sequenced before commitment (§15.3, §17.4). ### B2. Employment and bonus (§15.4) | # | Item | Evidence expected | Corroboration | Section | |---|---|---|---|---| | 1 | The career | Employment contracts and appointment or promotion letters across the period | Employer confirmations where obtainable | §15.4 | | 2 | Cash remuneration | Payslips or annual compensation statements | Bank credits at item 5 | §15.4 | | 3 | Variable and equity remuneration | Bonus, share-scheme and option documentation, including grants, vesting and sale records | Contract notes and sale proceeds | §15.4 | | 4 | Tax position | Personal tax filings for the accumulation years | The tax-filing consistency test at E1 | §15.4, §15.13 | | 5 | The accumulation itself | Bank and investment statements showing the position being built | Arithmetic plausibility test below | §15.4 | Table F.3 — salaried-executive pack. Assumptions: a documented employment history in one or more jurisdictions that issue payslips and returns. Derived from §15.4. The central test is arithmetic: declared net income over the period, less the visible cost of the client's life, must credibly produce the wealth claimed. A remuneration history that cannot arithmetically support the declared position is among the commonest inconsistencies found (E2), and is better identified by the client's own advisers before filing than by a due-diligence provider after it (§15.4). ### B3. Property-sale proceeds (§15.5) | # | Item | Evidence expected | Direction | Section | |---|---|---|---|---| | 1 | The asset sold | Title documents for the property, evidence of its original acquisition and of how that acquisition was funded | Backward, to the wealth | §15.5 | | 2 | The disposal | Sale agreement and completion statement | Forward, to the funds | §15.5 | | 3 | Receipt | Bank credit of the net proceeds into the client's account | Forward, to the funds | §15.5 | | 4 | Tax position | Tax filings recognising the disposal, where the seller's jurisdiction taxes it | Cross-check at E1 | §15.5, §15.13 | Table F.4 — property-sale pack. Assumptions: an arm's-length disposal of an asset held in the client's own name; where the asset was held through a structure, the beneficial-ownership chain is documented to the same standard (§15.7). Derived from §15.5. The backward direction is the one most often missed: a sale evidences the funds, not the wealth, so the original purchase must itself be explicable from the earlier wealth history. For long-held assets the contemporaneous record may be thin; land-registry archives, historical bank records and proportionate professional reconstruction are the usual answer, and the age of a holding is itself a mitigating fact when documented (§15.5). ### B4. Inheritance (§15.6) | # | Item | Evidence expected | Corroboration | Section | |---|---|---|---|---| | 1 | The entitlement | Will, grant of probate, deed of succession or equivalent instrument | — | §15.6 | | 2 | The quantum | Estate accounts, or the executor's or notary's distribution statement | Reconciliation with item 4 | §15.6 | | 3 | Fiscal clearance | Inheritance-tax filings or clearance certificates, where the estate's jurisdiction imposes them | — | §15.6 | | 4 | Completion of the chain | The bank transfer from the estate to the client | The trail at C | §15.6 | Table F.5 — inheritance pack. Assumptions: an estate administered in a jurisdiction that issues the instruments listed; where risk indicators are present, due diligence looks through to the deceased's own source of wealth. Derived from §15.6. The look-through rests on recorded typology, not distrust of heirs: the joint report finds it common for high-risk individuals to gift wealth to a spouse or other family member who then makes the lead application, citing cases in which the spouses of politically exposed persons applied as principals (§15.6, §15.10). Large lifetime gifts received shortly before an application are examined on the same principle, with the donor's identity, relationship and source of wealth evidenced (B6, §15.8). ### B5. Dividends and investment income (§15.7) | # | Item | Evidence expected | Corroboration | Section | |---|---|---|---|---| | 1 | The portfolio over time | Custody and brokerage statements across the holding period | — | §15.7 | | 2 | The distributions | Dividend vouchers or distribution statements; for private companies, the accounts and resolutions behind each distribution | B1 items 2 and 4 | §15.7, §15.3 | | 3 | Realisations feeding the payment | Contract notes for significant disposals feeding the paying account | The trail at C | §15.7 | | 4 | Tax position | Tax filings declaring the income in the client's jurisdiction(s) of tax residence | The tax-filing consistency test at E1 | §15.7, §15.13 | Table F.6 — investment-income pack. Assumptions: investment income is derivative, so the capital producing it must itself be explained under one of the other packs — the distributions are source of funds, the portfolio's origin is source of wealth. Where the portfolio is held through structures, the beneficial-ownership chain is documented to the same standard as the income. Derived from §15.7. The chief test is consistency with the tax record: income said to have accumulated over years should appear, year by year, in the filings of the jurisdiction that taxes it (§15.7, §15.13). ### B6. Loans and third-party funding (§15.8) Third-party funding is not always improper, but every payer becomes part of the file. The dividing line is not whether someone else pays; it is whether the payer, the relationship and the payer's own wealth can be evidenced as fully as the applicant's (§15.8). | # | Item | Evidence expected | Qualification stated in the body | Section | |---|---|---|---|---| | 1 | Identity and relationship of every payer | Identity documents, proof of relationship, and the payer's own wealth and funds packs at B1–B5 or B7 | The finances of accompanying family members are within the stated scope of the examination | §15.8, §15.2 | | 2 | Family payment of the property price | Payment by the buyer's spouse or by relatives by blood or marriage up to the second degree, with every payment detail recorded in the notarial deed (Law 5038/2023, Art. 100 §§5–6) | Permitted category is exhaustive as drawn by the article; the notary certifies parties, price, payment method and full payment | §15.8, §15.12 | | 3 | Third-party payment of the contribution | Not provided for: the decree's only mechanic is deposit by the applicant into the National Transformation Fund's exclusive bank account with a bank-documented declaration of lawful origin (Decreto-Lei n.º 07/2025, Arts. 8 and 14(4), Anexo III item 6) | The decree is silent on third-party payment; any funding otherwise than from the applicant's own resources requires confirmation with the programme's responsible unit at the date of application | §15.8 | | 4 | Commercial borrowing | Loan agreement with a regulated lender, commercial terms, security over other assets of the client, and repayment serviceable from identified income | A loan explains liquidity, not wealth; the source of wealth must stand independently of it | §15.8, §15.2 | | 5 | Borrowing connected with the qualifying acquisition | Confirmation by Greek counsel before any borrowing is relied on | Circular 1/2026 of the Secretary General for Migration Policy is reported to direct that permits may be revoked where arrangements reduce the effective investment below the statutory minimum; the circular text is not published and the position requires confirmation at the date of application | §15.8 | | 6 | Gifts | Donor's identity, relationship and source of wealth, evidenced to the applicant's standard | Gifts received shortly before an application without evidence of the donor's source of wealth are a documented red flag | §15.8, §15.6 | Table F.7 — third-party funding and lending. Assumptions: the reference structure's two statutory payment architectures as described in §15.1 and §15.12; item 5 carries a REPORTED-tier source and is stated as requiring confirmation. Derived from §15.8. Documented red-flag typologies, each of which takes the file to F: funds routed through parties whose identity or role cannot be explained; remittances from unconnected companies, particularly offshore entities with no visible relationship to the applicant (recorded in the joint report as a layering case study); gifts as at item 6; and loans from unregulated or unidentifiable lenders, loans without commercial terms or repayment mechanics, and loans repayable to parties other than the stated lender (§15.8). ### B7. Digital assets (§15.9) Crypto-derived wealth is not, in itself, a ground for declining a client. It is the wealth type with the most demanding evidence standard, and neither component of the reference structure accepts digital assets as payment: Greek law fixes the property payment channels exhaustively as bank instruments (Law 5038/2023, Art. 100 §§5–6) and the São Tomé decree's only mechanic is a bank deposit into the National Transformation Fund's exclusive account (Decreto-Lei n.º 07/2025, Arts. 8 and 14(4)). Crypto-origin wealth must therefore be converted into euro or dollars through a regulated institution and arrive as a bank transfer (§15.9). | # | Item | Evidence expected | Weight | Section | |---|---|---|---|---| | 1 | Provider records | Account and transaction records from licensed or registered virtual-asset service providers | Primary evidence; FATF Recommendation 15 requires such providers to be licensed or registered and regulated, so a compliant history should carry a trail by design | §15.9 | | 2 | On-chain tracing | An on-chain analytics report from a recognised provider linking the relevant wallets to the client and to the disposal that produced the fiat proceeds | Corroboration, not proof: FATF both recommends blockchain analytics in higher-risk situations and records their limitations of coverage, timeliness, accuracy and reliability | §15.9 | | 3 | Tax position | Consistency with the client's tax filings for the acquisition, holding and disposal of the assets | The tax-filing consistency test at E1 | §15.9, §15.13 | | 4 | Conversion and payment | Conversion to fiat through a regulated institution, with the programme payments made by bank transfer as both statutes require | Mandatory: the statutory payment channels admit nothing else | §15.9, §15.1 | Table F.8 — digital-asset pack; all four items are required together, not in the alternative. Assumptions: wealth generated or held in virtual assets and realised into fiat before payment; FATF treats virtual assets as property and funds for the purposes of every Recommendation, so the Recommendation 10 source-of-funds duty applies exactly as to any other asset class. Derived from §15.9. Comparative note: the St Kitts and Nevis Citizenship by Investment Unit states on its official site that it accepts cryptocurrency as a partial source of wealth, requiring separate proof of non-crypto wealth and additional due-diligence fees — a practice-level, undated statement for a different programme; no equivalent published position exists for either component of the reference structure (§15.9). ### B8. Pack sizes | Pack | Wealth type | Evidence items | Section | |---|---|---|---| | B1 | Business ownership and sale | 6 | §15.3 | | B2 | Employment and bonus | 5 | §15.4 | | B3 | Property-sale proceeds | 4 | §15.5 | | B4 | Inheritance | 4 | §15.6 | | B5 | Dividends and investment income | 4 | §15.7 | | B6 | Loans and third-party funding | 6 | §15.8 | | B7 | Digital assets | 4 | §15.9 | | **Total** | **Seven wealth types** | **33** | **§15.3–§15.9** | Table F.9 — item count across Section B, for file-planning purposes only. Assumptions: counts are of the rows printed at B1–B7 in this appendix and foot to 33 (6 + 5 + 4 + 4 + 4 + 6 + 4); a client with wealth from more than one source assembles more than one pack, and the counts do not include the money trail at C, screening at D, family documentation (Chapter 16) or the formalities at E. Derived from §15.3–§15.9. --- ## C. The money trail Source of funds is a chain, and the file must close every link of it. The statutory endpoints are fixed and admit no discretion (§15.1). | # | Check | Evidence expected | Section | |---|---|---|---| | 1 | Origin identified | The specific monies are attributed to a named wealth event evidenced in a Section B pack, not to the client's wealth in general | §15.2 | | 2 | Every intermediate account named | Statements for each account through which the funds passed, with the account holder identified; no unexplained intermediate accounts | §15.12, §15.13 | | 3 | No cash steps | A complete bank trail end to end; cash steps break the chain because they cannot be evidenced | §15.12 | | 4 | No unexplained third parties | Every payer and every counterparty in the path explained and evidenced under B6; funds routed through parties whose identity or role cannot be explained are a deferral criterion in their own right | §15.8, §15.13, §15.14 | | 5 | Arrival at the paying account | Statements showing the funds in the account from which each statutory payment will be made | §15.2 | | 6 | Property payment through the statutory channel | Crossed bank cheque to an account with a credit institution operating in Greece, credit transfer, or payment through a payment provider operating in Greece, certified by the notary in the deed as to parties, price, payment method and full payment (Law 5038/2023, Art. 100 §§5–6) | §15.1, §15.12 | | 7 | Contribution payment through the statutory channel | Deposit into the National Transformation Fund's exclusive bank account, through banking channels, within 90 days of approval, with the declaration of lawful origin supported by bank documentation (Decreto-Lei n.º 07/2025, Arts. 8 and 14(4), Anexo III item 6) | §15.1, §15.12 | | 8 | Valuation consistent with the market | Pricing evidence for the qualifying property; outliers attract institutional attention | §15.13, §8.3 | Table F.10 — the funds chain, seven links plus the valuation check that sits alongside them. Assumptions: the contribution is payable only after approval and the qualifying property is acquired in full before the residence application is made, so the two payments occur at different points in the sequence (§15.1, §17.10–§17.11). Derived from §15.1, §15.2, §15.8, §15.12, §15.13. Item 8 responds to reported schemes in which properties worth less than €100,000 were resold to foreign buyers at or above the €250,000 threshold, and to simulated transactions organised to abuse that threshold, recorded from Hellenic Financial Intelligence Unit submissions (§15.13). --- ## D. Screening Screening is the part of due diligence for which the client discloses rather than prepares (§15.11). Each vetting layer is expected to screen independently and not to rely on screening undertaken by another layer, so the same facts are examined several times and the file must read identically at each (§15.12). | # | Element | What is screened, and what the file provides | Section | |---|---|---|---| | 1 | Politically exposed person status | Whether the client is or has been entrusted with prominent public functions by a foreign country — heads of state or government, senior politicians, senior government, judicial or military officials, senior executives of state-owned corporations, important political party officials; FATF's definition expressly does not extend to middle-ranking or more junior individuals | §15.10 | | 2 | Family members and close associates | The same enquiry across the family group; Regulation (EU) 2024/1624 defines family members and known close associates, and the joint report's typology is that a cleaner family name is commonly placed on the application | §15.10, §15.6 | | 3 | Consequences where PEP status applies | Escalated approval within each institution; the deepest source-of-wealth work of any client profile, particularly where the wealth narrative and the public function overlap in time; longer timelines. PEP status is not an accusation — the EU measures are expressly preventive, not criminal, in nature. No outcome can be guaranteed for any client, PEP or otherwise | §15.10 | | 4 | Sanctions lists | United Nations targeted financial sanctions and domestic and multinational regimes; in practice at least the United Nations, European Union, United States (OFAC) and United Kingdom lists, together with national lists relevant to the client's countries of nationality, residence and business. The UN/EU/OFAC/UK formulation describes programme and institutional practice, not FATF wording | §15.11 | | 5 | Re-screening | Annual re-screening of approved names against Interpol systems and international sanctions lists; screening is repeated over the life of the relationship, not performed once at the gate | §15.11, §15.1 | | 6 | Adverse media | Open-source and media searches in the language or languages of the client's jurisdictions of origin and of close association, not in English alone | §15.11 | | 7 | All identities and all nationalities | Every name and nationality held or formerly held, stated plainly in the file — former names, transliterations and married names included — so that screening can be run and cleared against each. The joint report directs financial institutions to establish that all nationalities and passports are disclosed at onboarding, and Regulation (EU) 2024/1624, Art. 22(1)(a) requires collection of all nationalities held | §15.11, §9.4 | | 8 | Programme-level screening | On the citizenship side, due diligence by independent external entities and a consultative Review Committee chaired by a representative of the Public Prosecutor with the Financial Intelligence Unit among its members, which verifies anti-money-laundering and counter-terrorist-financing compliance and may suspend a file as a precaution (Decreto-Lei n.º 07/2025, Arts. 9 and 11); the Public Prosecutor's prior clearance; and judicial opposition available for six months after acquisition | §15.11, §15.1, §6.5, §6.8 | | 9 | Nationality-linked restrictions | The Government of São Tomé and Príncipe may exclude applicants of designated nationalities by gazetted resolution (Decreto-Lei n.º 07/2025, Art. 17); no such resolution had been located as at 2 August 2026, and the position requires confirmation at the date of application. European Union restrictive measures affecting Russian and Belarusian nationals are assessed within the nationality-specific analysis | §15.11, §13.2 | | 10 | Match resolution | Most matches are false positives, resolved with identifiers — dates of birth, passport numbers, corroborating documents. A match that cannot be resolved, or that is true, takes the application to Section F | §15.11, §15.14 | Table F.11 — screening elements. Assumptions: the background to item 7 is the identity-laundering typology recorded in the joint report — passports acquired under different names or with slightly altered details to defeat database screening — and the practical consequence for a legitimate applicant is the opposite of concealment. Derived from §15.10, §15.11, §15.12. Rows 8 and 9 state the position as at 2 August 2026. > **Full identity and no obfuscation (§15.11).** This is Kestrel Private's standing policy and a condition of the engagement, not a statement of preference. Every present and former nationality is disclosed wherever it is required or materially relevant, and the client's original nationality is never concealed by presenting only a newly acquired passport. Aliases, former names, married and transliterated names, and every identity document the client holds or has held are disclosed in the same terms. Material refusals — of a visa, a residence permit, a citizenship application, a banking relationship or a regulatory authorisation — are disclosed where they are requested or relevant, and at the point at which they are asked about rather than after they are discovered. Source-of-wealth and source-of-funds review is conducted on the client's complete identity and complete financial history, not on the part of it that the newest document would support. A new nationality is never used to obscure the client's origin, sanctions exposure, adverse history, tax residence or an earlier refusal: the citizenship component does not displace the client's existing nationality, birthplace, tax residence or beneficial-ownership position in a financial institution's records (§6.11), and reporting under the Common Reporting Standard is keyed to the account holder's jurisdictions of tax residence and never to citizenship (§9.14). All tax residences, all beneficial ownership and all nationalities required by banks or by authorities are disclosed to them. Kestrel Private declines any client who seeks concealment of identity or origin, the avoidance of sanctions, a false claim of tax residence, the avoidance of reporting under the Common Reporting Standard, or the refiling of an application under a different identity to escape an earlier refusal. Each of those is a decline and not a deferral: the deficiency is structural rather than evidential, and the criteria at §13.14 and §15.14 apply to it in terms. --- ## E. Consistency checks Files seldom fail for absence of wealth; they fail for inconsistency between what is claimed and what the documents, checked against one another, actually show. The order below is the chapter's approximate order of frequency and consequence (§15.13). | # | Check | What the examiner compares | Consequence if unresolved | Section | |---|---|---|---|---| | E1 | The tax-filing test | The stated wealth history against the tax record: wealth said to exist that appears in no return; income declared at levels that cannot support the claimed accumulation; disposals evidenced nowhere in the tax record of the jurisdiction that taxes them | Chief inconsistency, and a deferral criterion in its own right | §15.13, §15.14 | | E2 | Arithmetic gaps | Declared income over the period, less the visible cost of the client's life, against the accumulated position | Deferral pending explanation with documents | §15.13, §15.4 | | E3 | Breaks in the funds chain | Whether the specific investment funds can be traced from an identified wealth event to the paying account | Deferral pending documents; if the chain cannot be closed, do not proceed | §15.13, C | | E4 | Unexplained third parties | Every party in the payment path against the explanation given for its role | Deferral, or do not proceed where the role cannot be explained | §15.13, §15.8 | | E5 | Name and identity variations | Transliteration differences, post-marriage names and corporate aliases across all documents | Curable: reconcile and document rather than leave unexplained | §15.13, §15.11 | | E6 | Valuations against market evidence | The price of the qualifying property against market evidence; pricing outliers attract institutional attention | Property-side protections are Chapter 8's | §15.13, §8.3 | | E7 | Residence declarations against the banking footprint | Tax-residence self-certifications against the client's actual affairs; a financial institution may not rely on a self-certification it knows or has reason to know is incorrect or unreliable, and a Greek account held by a non-resident client will in any event be reported under the Common Reporting Standard to the client's jurisdiction(s) of tax residence | Any account of the client's affairs must be consistent with that transparency | §15.13, §9.4 | | E8 | Corporate records against the personal narrative | Shareholdings, dates and dormant entities against the profits attributed to them | Deferral pending reconciliation | §15.13, §15.3 | Table F.12 — the eight consistency checks. Assumptions: applied to the assembled file before filing, not after; many inconsistencies have innocent explanations — legacy record-keeping, informal economies, decades-old transactions, translation artefacts — and the professional response is resolution before filing, with documents. Derived from §15.13. Explanation after refusal comes too late, and refusal itself becomes part of the client's record in subsequent applications of any kind (§15.13). **Formalities and currency of documents (§15.12).** The features of a file that clears layered examination are unglamorous: complete bank trails with no cash steps and no unexplained intermediate accounts; documents that reconcile with one another in names, dates and amounts; original-language documents paired with certified translations; and nothing left for the examiner to infer. Certificates age — the citizenship component's three-month rule for criminal-record certificates is the strictest requirement in the structure — so assembly is sequenced against the filing date rather than done far in advance (§15.12, §17.4). The citizenship-side formalities are set by Decreto-Lei n.º 07/2025, Art. 10 and Anexo III (official form in Portuguese or English; criminal-record certificates from each country of nationality and of residence in the last five years; certified translations; Hague Apostille or, in its absence, consular authentication; declaration of lawful origin of funds with bank documentation; due-diligence report by a recognised entity). On the residence side the documentary schedule is fixed by joint ministerial decision and the notarial deed itself certifies price, payment method and full payment. Family members' documents are prepared to the same standard (Chapter 16). --- ## F. Deferral and non-filing triggers Deferral is a professional obligation, not a commercial disappointment. The institutions in the chain are themselves bound to refuse where due diligence cannot be completed: FATF Recommendation 10 directs that the institution should not establish the relationship and should consider a suspicious-transaction report; Law 4557/2018, Art. 13 obliges refusal in the same circumstances; and from 10 July 2027 Regulation (EU) 2024/1624, Art. 21(1) carries the same duty. A file that would fail these tests should not be submitted in the hope of a different answer (§15.14). Concealment of identity or origin is dealt with separately in the policy statement at D, where it is a decline and not a deferral (§15.11). ### F1. Defer, and continue preparation — the deficiency is evidential and realistically curable | # | Trigger | Cure | Section | |---|---|---|---| | 1 | A material document exists but has not yet been obtained — probate, completion statement, registry extract, provider records | Obtain it; reconstruction through independent accountants and historical records where the original is lost | §15.14, §15.3 | | 2 | The funds chain has gaps that further documentation can close | Close each link at C | §15.14, C | | 3 | Screening matches remain unresolved but appear resolvable with identifiers | Resolve with dates of birth, passport numbers and corroborating documents | §15.14, §15.11 | | 4 | Certificates have aged past their validity | Reissue against a new filing date and sequence assembly accordingly | §15.14, §15.12, §17.4 | Table F.13 — deferral triggers. Assumptions: deferral presumes the underlying position is sound and the deficiency documentary. Derived from §15.14, §15.12. ### F2. Do not proceed — the position is structural | # | Trigger | Section | |---|---|---| | 1 | The source of wealth cannot be explained and evidenced | §15.14, §15.2 | | 2 | The specific investment funds cannot be traced | §15.14, C | | 3 | Tax filings conflict materially with the stated wealth history and the conflict cannot be resolved | §15.14, E1 | | 4 | Funds have passed through third parties whose role cannot be explained | §15.14, §15.8 | | 5 | Sanctions, criminal or material regulatory concerns cannot be resolved | §15.14, §15.11 | | 6 | The client expects guaranteed banking, immigration or tax outcomes | §15.14, §13.10 | Table F.14 — non-filing criteria, mirroring the criteria stated in Chapter 1 and treated more fully at §13.10 and §13.14, which include criteria unrelated to funds. Assumptions: these are structural rather than documentary; where the standard can never be met, the structure should not be attempted. Derived from §15.14. ### F3. Wealth-type-specific triggers | # | Trigger | Treatment | Section | |---|---|---|---| | 1 | Material exposure to mixers, tumblers or anonymity-enhanced coins | Defer until resolved | §15.9 | | 2 | Wealth histories resting on peer-to-peer transactions with no provider records | Defer until resolved | §15.9 | | 3 | Use of unlicensed or since-collapsed platforms whose records cannot be obtained | Defer until resolved | §15.9 | | 4 | Inability to demonstrate control of the originating wallets | Defer until resolved | §15.9 | | 5 | Counterparty exposure to sanctioned addresses or darknet marketplaces | Defer until resolved | §15.9 | | 6 | Any indication that the client values the new documents as a means of onboarding with virtual-asset service providers under a changed identity | Not a deferral trigger — a decline signal | §15.9 | | 7 | Recent prominent public functions where the wealth cannot be evidenced independently of them | The honest advice is F2 | §15.10 | Table F.15 — additional triggers arising from particular wealth types and profiles; items 1 to 6 map to FATF's published red-flag indicator families for virtual assets. Assumptions: items 1 to 5 defer the application until resolved and are not, in themselves, grounds for decline — crypto-origin wealth is not a ground for declining a client (§15.9). Derived from §15.9, §15.10. **Why deferral serves the client (§15.14).** The sunk costs of a failed application are real: the citizenship component's due-diligence fee is non-refundable after submission, and the process lapses if the Public Prosecutor's clearance is refused. The residence sequencing means a late funds failure can leave the client owning a Greek property without the permit it was bought to support (§14.7). And approvals obtained on weak files are not durable assets: the citizenship component carries a six-month judicial-opposition window and revocation among its defined sanctions, and the Cypriot post-programme review demonstrates retrospective enforcement at scale (§2.2, §15.1). An application deferred until it is evidenced is slower; an application refused — or granted and then opposed — is worse. Where the evidence standard cannot yet be met, the file is not ready; where it can never be met, the structure should not be attempted (§13.14). The decision on any application that is filed rests, in every case, with the governments concerned (§18.9).