
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
Learn how international graduates can stay in France for one year to find work or start a business. Discover eligibility requirements, application steps and transition options for the Job Seeker/New Business Creator permit.
Media mentions
In an article published in Mens en Migratie magazine, Senior Associate Tugba Ozyakup explains how authorized representatives support employers with recognized sponsor status by managing complex immigration processes, particularly for international companies navigating Dutch requirements.
Media mentions
Video
Manager Mihaela Dumitru highlights key considerations for business travelers entering Switzerland, emphasizing that compliance is determined by activities—not duration of stay or entry status.
Video
Partner Rick Lamanna, Senior Associate Jake Paul Minster and Senior Manager Sergio Flores discuss Mexico entry requirements for the 2026 FIFA World Cup, including visa processes, documentation requirements and key considerations for travelers.
Video
Partner Diana Quintas highlights Brazil’s offshore visa requirements, including eligibility, application steps and key compliance considerations for assignments over 90 days.
Media mentions
Senior Counsel Mitch Wexler discusses why EB-5 is becoming a popular option for H-1B and F-1 visa holders in Silicon Valley navigating multiple pathways to permanent residence.
Media mentions
Partner Isha Atassi and Director Nofisatu Mojidi discuss key considerations for investors from Africa and the Middle East in the EB-5 program.
Work authorization
Senior Manager Katharina Vorländer examines how Germany’s strictly territorial migration and employment laws impact the deployment of third‑country nationals in offshore wind projects, highlighting compliance risks arising from maritime zone boundaries, work authorization limits and Schengen documentation challenges.
Work authorization
Senior Associate Tugba Ozyakup and Senior Immigration Manager Andreia Ghimis explore how the EU’s Entry/Exit System is reshaping Schengen overstay enforcement, the risks facing travellers and employers and the legal remedies available to challenge or prevent adverse outcomes.
Video
Partner Rick Lamanna, Senior Associate Jake Paul Minster and Senior Manager Sergio Flores discuss Canada’s entry requirements for the 2026 FIFA World Cup, including visa-required and visa-exempt nationals, visitor entry rules and key planning considerations for fans, teams, media and volunteers.
Media mentions
Partner Kevin Miner discusses the DOL’s proposed H-1B wage rule and its potential to add significant unplanned costs for US employers.
Video
Learn how international graduates can stay in France for one year to find work or start a business. Discover eligibility requirements, application steps and transition options for the Job Seeker/New Business Creator permit.
Media mentions
In an article published in Mens en Migratie magazine, Senior Associate Tugba Ozyakup explains how authorized representatives support employers with recognized sponsor status by managing complex immigration processes, particularly for international companies navigating Dutch requirements.
Media mentions
Video
Manager Mihaela Dumitru highlights key considerations for business travelers entering Switzerland, emphasizing that compliance is determined by activities—not duration of stay or entry status.
Video
Partner Rick Lamanna, Senior Associate Jake Paul Minster and Senior Manager Sergio Flores discuss Mexico entry requirements for the 2026 FIFA World Cup, including visa processes, documentation requirements and key considerations for travelers.
Video
Partner Diana Quintas highlights Brazil’s offshore visa requirements, including eligibility, application steps and key compliance considerations for assignments over 90 days.
Media mentions
Senior Counsel Mitch Wexler discusses why EB-5 is becoming a popular option for H-1B and F-1 visa holders in Silicon Valley navigating multiple pathways to permanent residence.
Media mentions
Partner Isha Atassi and Director Nofisatu Mojidi discuss key considerations for investors from Africa and the Middle East in the EB-5 program.
Work authorization
Senior Manager Katharina Vorländer examines how Germany’s strictly territorial migration and employment laws impact the deployment of third‑country nationals in offshore wind projects, highlighting compliance risks arising from maritime zone boundaries, work authorization limits and Schengen documentation challenges.
Work authorization
Senior Associate Tugba Ozyakup and Senior Immigration Manager Andreia Ghimis explore how the EU’s Entry/Exit System is reshaping Schengen overstay enforcement, the risks facing travellers and employers and the legal remedies available to challenge or prevent adverse outcomes.
Video
Partner Rick Lamanna, Senior Associate Jake Paul Minster and Senior Manager Sergio Flores discuss Canada’s entry requirements for the 2026 FIFA World Cup, including visa-required and visa-exempt nationals, visitor entry rules and key planning considerations for fans, teams, media and volunteers.
Media mentions
Partner Kevin Miner discusses the DOL’s proposed H-1B wage rule and its potential to add significant unplanned costs for US employers.

