The original purchase records and financing of the hotel, tax returns showing its income over the ownership period, the sale agreement and closing statement, proof the gain was reported, and bank statements tracing the proceeds, including currency conversion, into the enterprise's escrow account. Personal identity and civil documents for all family members complete the file.
Document the hotel from acquisition to sale, then the money from sale to escrow
Officers examine source and path separately. For source, the Okonjos should produce the agreement under which they originally bought the hotel, the mortgage documents and evidence of how the down payment was funded, and business tax returns showing lawful operating income since. Then the sale: the listing, the sale agreement, the closing statement, and the tax filing reporting the disposition. For path, every account through which the proceeds passed must be shown with statements, and any exchange of Canadian dollars into U.S. dollars documented with the exchange confirmation. A short chronology tying each document to a date and amount prevents the reviewer from reconstructing it. Add passports, birth and marriage certificates for the family, and the enterprise's subscription and escrow agreements. If part of the capital comes from savings unrelated to the hotel, that stream needs its own trail.
Hypothetical example: An art-gallery owner funds an investment from the staged sale of a collection and business inventory. The first review traces each sale through contracts, invoices, payment records, tax reporting and bank statements before the funds enter the investment account. If a gift, loan or sale occurred years earlier, the donor, lender or buyer records may also be necessary. The most important decision is whether a clean trace can be assembled before subscription. A large balance alone does not establish lawful source and path, and unexplained cash deposits can complicate an otherwise credible file.