As of May 2026, Dominica CBIU is rewriting source-of-funds and source-of-wealth scrutiny against the FATF 2024 revision standard. The most serious compliance tightening the program has done in 11 years. For cross-border trading clients with multi-jurisdiction money chains, the days of clearing DD with three bank statements and one audit report are over.
I have spent the past two weeks at home in LA walking clients through this. Four sentences:
One. Source of funds and source of wealth are now two separate reviews. The first explains how this specific tranche of money was earned. The second explains how the applicant's lifetime wealth was accumulated. Clients used to merge them into one asset statement, and CBIU now bounces the file.
Two. The restricted-nationality list is being grouped by risk tier, no longer the simple "Iran, North Korea, Afghanistan" blacklist. The new framework grades by FATF grey-list status and sanctions exposure. Cross-border trading clients on otherwise clean passports still get scrutinized if their customer base sits in higher-risk geographies (for instance, RUS or TUR client share).
Three. The funds chain has to be traceable to a verifiable lawful origin. A "company dividend, then personal account" trail is not enough. CBIU traces upstream to corporate profit, customer contracts, and tax filings.
Four. Pass-through accounts in crypto or offshore structures must be voluntarily disclosed. Concealment that is later discovered means refusal plus a 5-year reapplication ban.
| Field | Detail |
|---|---|
| Investment | $200,000 floor (EDF route, lowest of the Caribbean five) |
| Processing | 6-8 months (DD itself 3-9 months, drifting toward 9 post-FATF) |
| Visa-free | 140+ countries, includes Schengen, UK access removed July 2023 |
| Schengen / UK / E-2 / China | Schengen | UK ✗ | E-2 ✗ | China conditional |
| Family | Applicant, spouse, children, parents and grandparents 55+ |
| 2027 airport | International airport opening 2027 — long-term value anchor |
Client profile (anonymized, in process April 2026)
A cross-border trading entrepreneur, 46. Family business in appliance export for 18 years. Primary markets are Middle East and Southeast Asia. Annual flow ¥800M-¥1.2B. He came to me after his offshore bank started a CRS-driven source-of-funds review and froze the account for six weeks. Classic global identity diversification motive — Plan B.
The first time we sat with his documents, I said this: your source-of-funds story has to run from corporate profit to customer contract to export declaration to tax filing without a break. If any link snaps, Dominica CBIU under the FATF revision will refuse.
We spent five weeks on compliance pre-review and document organization. The output was an 80-page source-of-funds and source-of-wealth report covering seven years of customer contracts, export declarations, bank statements, and tax filings. Week six, the DD package went to CBIU.
[Ken's call] Not the most expensive, not the cheapest — only the most appropriate. The reason he fits Dominica is not that it is cheapest. The reason is that his funds chain actually clears the FATF revision. If any link of his story had broken, I would have told him to pause CBI and fix the compliance story before paying any DD fee.
First, sort the past 5-7 years of core commercial contracts, bank statements, and tax filings into a reverse chronological binder. This binder is for you, not CBIU. Whether you can tell this story matters more than how CBIU will review it.
Second, do not pay the DD fee and then scramble to backfill documents. Dominica DD is $7,500 base for the main applicant. A four-person family with full DD lands at $14,000-$18,000. Pay it and get refused, with no refund.
Third, accept the new reality. As of May 2026, Dominica is no longer the cheap-route shorthand. The accurate label is "the lowest entry that still clears FATF standards." Two different positionings. Which one you accept determines whether you spend five weeks on compliance pre-review.
You may be wondering whether your company's funds chain clears FATF. That question is exactly why we built the 2026 Eight-Passport CBI Decision Map PDF — 26 pages including a "source-of-funds and source-of-wealth self-check list" so you can spend 30 minutes deciding before paying any DD fee.
Message me on WhatsApp +15595666666 with "map." I send the PDF myself. Free. No email needed.
If your bank already opened a source-of-funds review or your account was frozen or flagged, message WhatsApp +15595666666 (note "decision map"). Fifteen minutes is enough for me to tell you whether to apply, hold, or solve the bank side first. No fees. If it does not fit, I say so.
Full materials and 70+ real approval cases: WWW.USA60.COM
A: As of May 2026, Dominica CBIU runs source of funds (how this tranche was earned) and source of wealth (how the lifetime wealth accumulated) as two separate reviews. The old practice of merging them into one asset statement now triggers an automatic file return.
A: No. As of May 2026, the core question for cross-border traders is whether the funds chain traces from corporate profit back to original contracts and tax filings. If it does, DD still passes. If it does not, plan a 5-8 week compliance pre-review before submitting.
A: As of May 2026, a four-person family on the EDF route lands at $280,000-$310,000 total (DD, government, legal, source-of-funds reporting fees included). $200K is the single-applicant EDF entry, not the four-person total.
A: As of May 2026, the new airport is a 5-10 year long-term value anchor for real estate, tourism, and commercial activity. It should not be the core reason to apply today. Today's reasons are: source-of-funds path still works, Schengen visa-free, and a low total bill. The airport is a bonus.
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