
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
Media mentions
Senior Manager Katharina Vorländer explains how employers and clients can reduce legal risks during cross-border employee assignments in Germany.
Blog post
Senior Manager Zak Hynes explores the key factors businesses should consider when establishing a presence in the UAE—from operating model and visa requirements to banking, office needs and long-term growth plans—in our new blog. The right structure is the one that best supports your business strategy, not simply the lowest upfront cost.
Video
Partner Catherine Macris highlights key findings from Fragomen’s 2026 regional immigration overviews, including tighter compliance controls, digital border transformation and emerging pathways for global talent.
Media mentions
Partner Karolina Schiffter discusses how the EU's extension of temporary protection for Ukrainian citizens through 2028 will affect employers in Poland.
Fragomen news
Fragomen’s "Immigration Guide for the UK Tech Sector" introduces visa options available for those working and recruiting in the tech sector.
Blog post
Center for Strategy and Applied Insights Senior Director Leah Rogal examines how employers can use the J-1 Research Scholar visa to retain eligible global research talent, support long-term research initiatives and strengthen workforce and immigration planning.
Blog post
In this blog, Middle East and Africa Private Client Practice Director Nofi Mojidi-Bayna explores how evolving residency frameworks across the region are reshaping long-term mobility planning and examines the three global forces transforming immigration strategy for businesses, investors and internationally mobile families.
Blog post
In this blog, Associate Halil Kaya outlines the UK Visa Fees Reimbursement Scheme for Scale Ups, including eligibility requirements, available funding and key considerations for high-growth businesses recruiting international talent.
Media mentions
Blog post
Media mentions
Senior Associate Isabel Schnitzler outlines the key compliance considerations for employers with employees working across the EU.
Media mentions
Media mentions
Senior Manager Katharina Vorländer explains how employers and clients can reduce legal risks during cross-border employee assignments in Germany.
Blog post
Senior Manager Zak Hynes explores the key factors businesses should consider when establishing a presence in the UAE—from operating model and visa requirements to banking, office needs and long-term growth plans—in our new blog. The right structure is the one that best supports your business strategy, not simply the lowest upfront cost.
Video
Partner Catherine Macris highlights key findings from Fragomen’s 2026 regional immigration overviews, including tighter compliance controls, digital border transformation and emerging pathways for global talent.
Media mentions
Partner Karolina Schiffter discusses how the EU's extension of temporary protection for Ukrainian citizens through 2028 will affect employers in Poland.
Fragomen news
Fragomen’s "Immigration Guide for the UK Tech Sector" introduces visa options available for those working and recruiting in the tech sector.
Blog post
Center for Strategy and Applied Insights Senior Director Leah Rogal examines how employers can use the J-1 Research Scholar visa to retain eligible global research talent, support long-term research initiatives and strengthen workforce and immigration planning.
Blog post
In this blog, Middle East and Africa Private Client Practice Director Nofi Mojidi-Bayna explores how evolving residency frameworks across the region are reshaping long-term mobility planning and examines the three global forces transforming immigration strategy for businesses, investors and internationally mobile families.
Blog post
In this blog, Associate Halil Kaya outlines the UK Visa Fees Reimbursement Scheme for Scale Ups, including eligibility requirements, available funding and key considerations for high-growth businesses recruiting international talent.
Media mentions
Blog post
Media mentions
Senior Associate Isabel Schnitzler outlines the key compliance considerations for employers with employees working across the EU.

