
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
Video
In the Mobility Minute, Practice Leader Colm Collins outlines upcoming changes to Ireland’s employment permit qualifying criteria and the steps employers should take ahead of the 1 March 2026 implementation.
Media mentions
Partner Charlotte Slocombe discusses what travellers to the US under the Visa Waiver Program need to disclose and consider before travelling.
Media mentions
Counsel Brian Hunt discussed US Customs and Border Protection's proposed changes to the ESTA application process regarding social media and additional personal information.
Media mentions
Senior Counsel Mitch Wexler explains key considerations for Indian applicants under the new Gold Card program.
Video
In this Mobility Minute, Manager Maja Sugui outlines key legalisation requirements when the Apostille Convention does not apply or when country-specific exceptions exist.
Media mentions
Partner Bo Cooper highlights that visitors to the US under the visa waiver program for the 2026 World Cup could face a more extensive ESTA application process.
Media mentions
Partners Aaron Blumberg and K. Edward Raleigh outline how recent US visa policy changes affect H-1B and H-4 workers and how employers are adjusting compliance and work authorization processes.
Media mentions
Senior Manager Katharina Vorländer emphasizes the importance of legal support in helping skilled professionals navigate work-based immigration to Germany.
Blog post
The UK expands its High Potential Individual (HPI) visa for 2025, broadening eligibility for global graduates and entrepreneurs while introducing new requirements and application caps
Media mentions
Partner Bo Cooper discusses the US proposal to expand social media screening for visitors from visa waiver countries and the broader shift it represents in travel vetting.
Video
The latest Mobility Minute features Manager Alex Hood discussing recent updates to the UK’s High Potential Individual route, including expanded university eligibility, a new annual cap and modernized governance measures.
Media mentions
Managing Partner for the Middle East and Africa Murtaza Khan discusses how the UAE’s flexible migration policies attract talent and support a competitive labour market.
Video
In the Mobility Minute, Practice Leader Colm Collins outlines upcoming changes to Ireland’s employment permit qualifying criteria and the steps employers should take ahead of the 1 March 2026 implementation.
Media mentions
Partner Charlotte Slocombe discusses what travellers to the US under the Visa Waiver Program need to disclose and consider before travelling.
Media mentions
Counsel Brian Hunt discussed US Customs and Border Protection's proposed changes to the ESTA application process regarding social media and additional personal information.
Media mentions
Senior Counsel Mitch Wexler explains key considerations for Indian applicants under the new Gold Card program.
Video
In this Mobility Minute, Manager Maja Sugui outlines key legalisation requirements when the Apostille Convention does not apply or when country-specific exceptions exist.
Media mentions
Partner Bo Cooper highlights that visitors to the US under the visa waiver program for the 2026 World Cup could face a more extensive ESTA application process.
Media mentions
Partners Aaron Blumberg and K. Edward Raleigh outline how recent US visa policy changes affect H-1B and H-4 workers and how employers are adjusting compliance and work authorization processes.
Media mentions
Senior Manager Katharina Vorländer emphasizes the importance of legal support in helping skilled professionals navigate work-based immigration to Germany.
Blog post
The UK expands its High Potential Individual (HPI) visa for 2025, broadening eligibility for global graduates and entrepreneurs while introducing new requirements and application caps
Media mentions
Partner Bo Cooper discusses the US proposal to expand social media screening for visitors from visa waiver countries and the broader shift it represents in travel vetting.
Video
The latest Mobility Minute features Manager Alex Hood discussing recent updates to the UK’s High Potential Individual route, including expanded university eligibility, a new annual cap and modernized governance measures.
Media mentions
Managing Partner for the Middle East and Africa Murtaza Khan discusses how the UAE’s flexible migration policies attract talent and support a competitive labour market.

