
Country / Territory
Related contacts
Related offices
Related contacts
Related offices
Related contacts
Related offices
By: Rahul Soni
President Donald Trump announced Tuesday, February 25, 2025, that he intends to offer a new “Gold Card” with a pathway to US citizenship for a $5 million investment.
The administration noted that the “Trump Gold Card” would replace the 35-year-old EB-5 green card program within the next two weeks. Commerce Secretary Howard Lutnick commented that the “Gold Card” would eradicate issues of fraud associated with the current EB-5 program. In his announcement, President Trump did not mention any requirements of job-creation, as is the pinnacle of the current EB-5 process. He also noted that the “Gold Cards” would not require congressional approval.
Terminating the EB-5 Program?
An important question arises: can President Trump actually terminate the EB-5 program?
It is worth noting that in 2022, Congress affirmatively reauthorized the EB-5 “Regional Center” program through 2027 under the then-newly established EB-5 Reform and Integrity Act.
What does this mean for eliminating the current program? Practically speaking, eliminating EB-5 would mean enacting new legislation, passed through Congress. US federal immigration and nationality law is controlled by Congress and protected under the Constitution.
In reality, the “Gold Card” initiative, if implemented, may exist alongside the current EB-5 green card program, rather than replace it, creating an additional pathway to permanent residency and citizenship for ultra-high-net-worth individual (UHNWI) investors, by virtue of what seems to be (from President Trump’s initial proposal announcement) more of a donation-based model aimed at the ultra-wealthy, rather than a job-creation investment.
The administration’s “Gold Card” announcement seems to be a move to redefine and rebrand the current investment-based program in the US. This is not entirely dissimilar to what is happening in other jurisdictions around the world. In 2022, the UK terminated its investment-based residency program; various other residency-by-investment programs in the European Union were terminated or adjusted; and indeed, many of the Caribbean citizenship-by-investment programs significantly tightened their requirements.
Ultimately, in the US, changes may be expected, including the possibility of a new investment-based scheme as President Trump has proposed, targeted at UHNWI investors, to run in parallel with the EB-5 green card program.
Prospective EB-5 Investors
For prospective EB-5 investors, it is an excellent time to apply through the EB-5 program, and in fact, many benefits continue.
Under the Department of State’s upcoming “Visa Bulletin,” all nationalities, including India- and China-born nationals, remain current through certain expedited regional center projects, and can therefore still take advantage of quick processing times and fast green card issuance.
Further, once the initial EB-5 application (I-526E) is filed, as the law currently stands, the application will be protected, and in fact, the EB-5 Reform and Integrity Act maintains grandfathering provisions for investors who file before September 2026.
Need to know more?
For questions related to the EB-5 Immigrant Investor Visa Program, or to initiate an EB-5 application, please contact Partner Rahul Soni at [email protected].
This blog was published on February 26, 2025, and due to the circumstances, there may be frequent changes. To keep up to date with all the latest updates on global immigration, please subscribe to our alerts and follow us on LinkedIn, X, Facebook and Instagram.
Country / Territory
Related contacts
Related offices
Related contacts
Related offices
Related contacts
Related offices
Explore more at Fragomen
Media mentions
Partner Karolina Schiffter explains why Poland has paused online residence permit bookings and returned to paper-based submissions.
Blog post
Senior Manager Ana Bessa Santos outlines Switzerland’s 2026 immigration quotas and what employers should expect across non-EU/EFTA, EU/EFTA and UK permit categories.
Blog post
Manager Ruaida Hussein outlines the UAE’s updated residency rules introducing a one-year residence permit for eligible individuals following divorce or the death of a spouse
Blog post
Partner Rahul Soni outlines USCIS’ decision to reduce EB-5 filing fees following a federal court ruling that invalidates the agency’s 2024 fee increases.
Media mentions
Manager Clara Gautrais and Immigration Paralegal Sean Pearce highlight how the UK government’s consultation on expanding right to work checks could affect construction employers.
Awards
China Managing Partner Becky Xia is named among the “Top 100 Most Influential Chinese Elites for 2025” by Forbes China for her leadership in immigration law and contributions to global mobility.
Awards
Fragomen is featured on The Times’ 2026 Best Law Firms list in the category of immigration.
Blog post
Senior Immigration Consultant Patricia Rezmives explains the 2025 process for claiming Irish citizenship through ancestry and key considerations for foreign birth registration.
Fragomen news
Fragomen is recognized on Law360 Pulse's 2025 Social Impact Leaders list.
Awards
Partner F. Joseph Paldino is recognized with the Utah State Bar’s Paul Moxley Outstanding Mentor Award for his dedication to mentorship in immigration law and fostering professional growth in the legal community.
Blog post
In this blog, Partner K. Edward Raleigh explains how modern immigration compliance must evolve from paperwork and formality into a strategic governance discipline that aligns outdated laws with today’s business realities and measures true compliance through systems, behavior and integrity.
Blog post
UK Government Affairs Strategy Director Shuyeb Muquit examines the UK’s evolving immigration framework, outlining recent reforms, upcoming consultations and the key areas where business can help shape the system’s future direction.
Media mentions
Partner Karolina Schiffter explains why Poland has paused online residence permit bookings and returned to paper-based submissions.
Blog post
Senior Manager Ana Bessa Santos outlines Switzerland’s 2026 immigration quotas and what employers should expect across non-EU/EFTA, EU/EFTA and UK permit categories.
Blog post
Manager Ruaida Hussein outlines the UAE’s updated residency rules introducing a one-year residence permit for eligible individuals following divorce or the death of a spouse
Blog post
Partner Rahul Soni outlines USCIS’ decision to reduce EB-5 filing fees following a federal court ruling that invalidates the agency’s 2024 fee increases.
Media mentions
Manager Clara Gautrais and Immigration Paralegal Sean Pearce highlight how the UK government’s consultation on expanding right to work checks could affect construction employers.
Awards
China Managing Partner Becky Xia is named among the “Top 100 Most Influential Chinese Elites for 2025” by Forbes China for her leadership in immigration law and contributions to global mobility.
Awards
Fragomen is featured on The Times’ 2026 Best Law Firms list in the category of immigration.
Blog post
Senior Immigration Consultant Patricia Rezmives explains the 2025 process for claiming Irish citizenship through ancestry and key considerations for foreign birth registration.
Fragomen news
Fragomen is recognized on Law360 Pulse's 2025 Social Impact Leaders list.
Awards
Partner F. Joseph Paldino is recognized with the Utah State Bar’s Paul Moxley Outstanding Mentor Award for his dedication to mentorship in immigration law and fostering professional growth in the legal community.
Blog post
In this blog, Partner K. Edward Raleigh explains how modern immigration compliance must evolve from paperwork and formality into a strategic governance discipline that aligns outdated laws with today’s business realities and measures true compliance through systems, behavior and integrity.
Blog post
UK Government Affairs Strategy Director Shuyeb Muquit examines the UK’s evolving immigration framework, outlining recent reforms, upcoming consultations and the key areas where business can help shape the system’s future direction.

