Hi all. For members who have already received their golden visa residency cards, could you please describe how rigorously the Portuguese authorities vetted the sources of the funds you used to make investments? Because mine mostly come from gifts from my Russian parents. Parents are regular business owners in Russia having nothing to do with sanctioned industries, persons or companies. And I’m just wondering whether this could pose any problems. I myself have no connection to Russia-no citizenship, no residence, nothing.
AFAIK AIMA is not directly involved; the government set the regulations for bank account opening, banks implement this thru KYC and anti-money laundering processes.
Each bank will be different and varies based on the perceived risk (amount/citizenship/location of inbound funds etc)
In my case , UK source, I supplied documents to support source of funds, plus standard proof of address/2 utility bills/ tax number / passport.
So once you open the PT bank account and the investment amount is accepted (including AML checks) you should be good with annual refresh of KYC documents.
Maybe others with Russian connections have a different experience, I don’t know….
There should be no issue if these gifts were coming in via wire transfers, i.e. if the funds you want to use are at your bank account now.
You can prepare the letters from your parents to be on a more safe side, but normally it is considered that the first bank which accepted the funds to your account should have performed the deeper check if required.
Hi All. Along the lines of this topic- If we are planning to apply for a golden visa with something like the Optimize fund (where there is no Portuguese bank account required), can we use gifted funds from parents? Coming from USA, the annual gift amount is $19,000 and taxes must be paid after that. So can a parent contribute a higher amount to your 500k euro by wiring it to Optimize without a tax penalty in the USA? Obviously I intend to speak with Optimize reps this week and this will be a question for them but just wondering if anyone else has had experience with funds from relatives to get to $500k.
The money has to come from an account under your name.
I’ve just been through this and I’ll share my experience. I can’t speak to every fund manager’s vetting process, but we tried to use an investment account my parents transferred to us in January (for this purpose) to invest in Pela Terra II, managed by STAG. I listed “Gift/Inheritance” as our source, which created big problems as my parents are living. I assumed as the account is held by a well known, international investment firm that it would be fine, but it was not because they couldn’t prove my 86 yr old parents’ source of funds without KYC for them. I didn’t want to put them through that so we had to figure out an alternative.
Our situation is complicated by other factors, but we learned too late that using Gifted funds is a red flag. Had I known that I think we could have avoided the delay (we started in Feb and are just getting our bank account funding source approved, a second hurdle). I think it would help to speak to someone who knows the ropes before you submit any documents, maybe listing the source in a different way or making sure your bank account is set up in a specific way could make all the difference. Also I’ve loved working with Pela Terra and believe in what they are doing, but going with an investment that doesn’t require a Portuguese bank account will save time and money. I hope this helps!
I’m not an American, but even if you figure out the KYC I wouldn’t have thought this gets round the gift limit in the US? As it would still be a gift to an account in your name, albeit overseas?
As an aside and coming from the investment management industry myself, third party transfers are a huge headache from a KYC perspective.
The US currently allows for a large transfer of family / estate wealth separate from the annual gift allowance.
Thanks so much for this info! We have investments in one of the largest wealth management firms in the USA, most of which is invested in regular stocks, ETF’s etc. My father in law has money with the same firm. Would you imagine he could transfer money into our account (well over the $19k gift limit) so that we could wire the money from this account to Optimize (or other qualifying GV fund) without this being an issue? I’ve been told a parent can transfer money over $19k with a written loan agreement that is not taxable as a gift.
There won’t be any tax if your parents gift you the needed funds (even if it’s more than $19/$38K) as long as they haven’t yet exceeded the lifetime gift tax exclusion of $13.99M per parent. They do however need to file IRS Form 709 when exceeding the $19K per year per parent threshold.
So don’t try to be clever with having your parents directly transferring money to Optimize or similar. Just have them make a bank transfer to you and file the required IRS form.
Not sure what Optimize would require in terms of source of funds in this case, however it could be that they would need to understand how your parents made this money in the first place.