The Gold Card Has Arrived

On September 19, 2025, Executive Order 14351 announced the Gold Card, a visa program to “facilitate the entry of aliens who have demonstrated their ability and desire to advance the interests of the United States by voluntarily providing a significant financial gift to the Nation.”
Under the Executive Order, the Secretaries of Commerce, State, and Homeland Security were required to implement the Gold Card Program within 90 days of the order or around December 19, 2025.

A full week ahead of the due date, on Thursday, December 11, 2025, the Trump Gold Card Program officially launched with a notification from Goldcard@list.commerce.gov. This article covers the state of play on the Trump Gold Card and shares what we know so far for investors interested in applying.

To start, notably, the December 11 e-mail was sent from the U.S. Department of Commerce, rather than the U.S. Department of Homeland Security, which houses all other U.S. immigration functions, including benefits as well as enforcement.

The Commerce e-mail invited the recipient to “visit trumpcard.gov to indicate which card you would like – the Trump Gold Card or the Trump Corporate Gold Card.” The e-mail also indicated that “the website has all the information needed to start the application process, as well as information on joining the waiting list for the new Trump Platinum Card.”

The Trumpcard.gov Website

The trumpcard.gov homepage opens with “Special Benefits” and shows in gold lettering a pathway “For Individuals” and in silver lettering “For Business.”  A bit confusing, but this page is “For Individuals”, and shows two boxes, one with the Trump Gold Card and the other with the Trump Platinum Card at $5 million (coming soon). Both the Trump Gold Card and the Trump Platinum Card are for individuals, and the page looks like this:

When you click on “For Business,” you are directed to the Trump Corporate Gold Card – the $2 million card for businesses and their employees. This area looks like this: 

“Apply Now” – Registration on Trumpcard.gov

In clicking the Apply Now button, you are taken to a page to “Choose Your Card.”  This is a registration page which must be completed to advance to filing the Form I-140G, discussed below.

When choosing the Individual – Trump Gold Card, you see the below with a simple one-page questionnaire for name, address, place of birth, and the number of dependents:

At the bottom is the payment prompt:

The author has not completed the form, but it is reported that the $15,000 DHS processing fee mentioned on the homepage boxes is chargeable per family member, with $375 added on top per applicant.

Once the DHS processing fee is paid, individuals will then need to complete the new Form I-140G, Immigrant Petition for the Gold Card Program.

Form I-140G

The first notable item is that the Form I-140G can only be filed through one’s USCIS online account. Thus, the Gold Card applicant must first have or create an online account.

The Form I-140G is 24 pages long and it queries 20 years of employment history, including any government or military positions held at any time. It also queries education history, including military academies or government-sponsored training. The Form also requires extensive attestations regarding admissibility and additional attestations to confirm that the Gold Card funds have never been subject to a foreign or domestic freeze order or injunction in the past 10 years for an offense involving financial fraud or deceit.

Regarding lawful source of funds, in answer to a question percolating since the September 19, 2025 Executive Order, the Gold Card Program appears to require a full vetting of lawful source of funds for the Gold Card contribution. 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.

Finally, 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.” 

Some Remaining Questions

Although the Gold Card application process is open now, it is all new, and questions remain. For example, we do not yet have wire transfer instructions to make the contribution. The payment of the contribution and date of transfer(s) to the Department of Commerce is required information on the Form I-140G (see below), but the trumpcard.gov website indicates that payment will be made upon receiving an email “after vetting is complete”. According to the website, the applicants should “instruct their banks to use an ACH debit or Swift Wire Transfer … according to the instructions provided at that time.” 

As another example, the Gold Card process seems to contemplate consular processing, although adjustment of status is generally available where there is visa availability and qualification under Immigration and Nationality Act § 245.

These questions and other potential legal challenges make clear that applicants interested in applying for the Gold Card must proceed with full awareness of the risks.

The Gold Card Program is new and involves a gift with no expectation of refund. Similarly, although the screening process, including Form I-140G online filing, suggests that the lawful source and path of funds once vetted should have a determinative effect, this is not assured. The filing fee in all cases is not refundable. The Form instruction also states that if the application does “not properly complete this petition, [she or he] will not establish a basis for … eligibility and [the Government] may reject or deny [the] petition.” Accordingly, while there is promise that “visa adjudication will take place on an expedited basis, assuming applicant submit any additional documents or fees in a timely manner,” no Gold Card has yet been issued under these procedures.

Conclusion

The Gold Card Program promises many features that will be attractive to many HNW and UHNW families around the world. The early applicants will have the opportunity to make history while also blazing the trail through uncharted new territory. Welcome to the new American frontier!