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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.
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