Gold Card Services

The Gold Card is a newly announced visa program under Executive Order dated September 19, 2025 to be overseen by the Secretary of Commerce, in coordination with the Secretary of State (DOS) and Secretary of Homeland Security (DHS).

It allows an immigrant visa applicant to qualify through a large, unrestricted financial gift to the U.S.  Department of Commerce deposited in a Commerce-managed Treasury fund. Quick parameters:

• Gift amount: $1 million (individuals) or $2 million (corporate/third-party sponsors).
• Legal basis: Treated as evidence of extraordinary ability under the employment-based first preference category (EB-1A), second preference category for exceptional ability (EB-2), and eligible for a national interest waiver (NIW) under the INA.
• Processing: Expedited adjudication and visa issuance are mandated.

The EB-5 Immigrant Investor Program requires investment in a U.S. commercial enterprise that creates jobs for U.S. workers under the employment-based fifth preference category. Investment must be “at risk,” but may be accompanied by hope and expectation of capital preservation and upside.

The Gold Card will be premised on an unconditional gift to the United States Treasury with no expectation of return of or on investment. It is not based on investment; rather, it’s a one-way gift.

The Gold Card is administered primarily by the Department of Commerce, with coordination from the Department of State (DOS) and the Department of Homeland Security (DHS).

Other visa programs, such as EB-5, are administered by USCIS (DHS) and DOS.

The Gold Card will be treated as qualifying evidence for employment based preference categories in the EB-1A and  EB-2 categories, eligible for National Interest Waiver (NIW) with expedited processing.

Yes. Under the Gold Card, a corporation or similar entity may contribute $2 million on behalf of an individual, essentially “sponsoring” the immigrant. The status can later be transferred to another individual designated by the corporation.

A full vetting of lawful source of funds for the Gold Card contribution is required. Part 4 of the Form I-140G is dedicated to Source of Funds and requires the sources of funds, an explanation, and supporting documentary evidence demonstrating lawfulness of the Gold Card contribution funds and filing fees. Types of funds include accumulated income, including from crypto funds traceable through blockchain and wallet identification, sale or mortgage of property, proceeds from ownership in a business, and other types of sources such as inheritance, legal proceedings, and insurance proceeds. Gifts are also permitted, requiring an explanation of the relationship between the giftor and the beneficiary, and a list of all the financial accounts of the Petitioner (the main Gold Card applicant) and spouse, if applicable.

The Gold Card promises expedited processing within a timeframe to be determined, most likely with actual adjudication.  

The two pathways are different.

The Gold Card requires no risk, as it requires an outright gift. However, this also means there is no return whatsoever of the contributed amount.

EB-5 requires risk, as it is an investment. However, an EB-5 project should never be risky, and there is hope and expectation of capital preservation, possible eventual return, and gain.

The Gold Card is best suited for ultra-high-net-worth individuals for whom a $1 million donation, with no expectation of return, is worth the promise of expedited U.S. residency. The Gold Card path may also be highly desirable for families with children nearing aging out (i.e., those who may turn 21 and therefore age out of dependent benefits), depending on how the guidelines establish expedited processing.

Because the Gold Card is newly created, it may also be the subject of various challenges, including in litigation. Unless memorialized by statute, it may also be revoked by a later administration, even if the issued Gold Cards are not.

It appears from both the Form I-140G, the Instructions, and the trumpcard.gov website that $1 million contribution is required for “each person requesting a Gold Card, including the principal beneficiary, any accompanying spouse, and any children listed on this petition who are also requesting a Gold Card.”

The EB-5 Green Card is best suited for investors for whom an investment with a hope of return (though remaining at risk) is important. These investors do not want to make an unconditional gift, and the prospect of preserving and receiving a return of capital at some point in the future is important, even while acknowledging the investment is at risk.

The EB-5 Green Card is also more suitable for investors for whom the $200,000 difference (for projects targeting employment areas) is a meaningful difference.

Finally, the EB-5 Green Card has the weight of a 35-year history behind it. Conservative investors will gravitate toward the hefty EB-5 bulwark.

Still, it is possible we will see individuals seeking both.

The first step is to register at trumpcard.gov. The registration page must be completed, and fees must be paid to advance to filing the Form I-140G. More here.

We will explore this new pathway and compare the Gold Card with the EB-5 pathway with you. Contact us for consultation.