President Trump’s “Gold Card” Proposal: A New Era For Investment-Based Immigration?

[Editor2]

On February 25, 2025, President Donald Trump announced a new initiative aimed at reshaping the U.S. investment-based immigration landscape. Dubbed the “Trump Gold Card,” this program offers a pathway to U.S. citizenship for individuals willing to invest $5 million. This move signals a potential overhaul of the long-standing EB-5 Immigrant Investor Program, which has been in place for 35 years.

The “Gold Card”: A Game Changer?​

According to the administration, the “Gold Card” will replace the EB-5 program within the next two weeks. Commerce Secretary Howard Lutnick stated that the new initiative is designed to eliminate fraud concerns that have plagued the existing EB-5 system. Notably, President Trump’s announcement did not mention any job-creation requirements, which are a fundamental aspect of the EB-5 program.

Another striking element of the “Gold Card” is that it does not require congressional approval. This raises questions about its legal feasibility and how it would be implemented without infringing on existing laws governing immigration and nationality.

Can the EB-5 Program Be Terminated?​

A crucial question that remains is whether the president has the authority to unilaterally terminate the EB-5 program. In 2022, Congress reauthorized the EB-5 Regional Center program through 2027 under the EB-5 Reform and Integrity Act. Given that immigration law is under congressional jurisdiction, eliminating the EB-5 program entirely would likely require legislative approval.

Instead of outright termination, it is more plausible that the “Gold Card” initiative will run parallel to the EB-5 program. Based on the limited details available, the “Gold Card” appears to be structured as a donation-based model aimed at ultra-high-net-worth individuals (UHNWI) rather than an investment-driven program tied to job creation.

Global Trends in Investment-Based Immigration​

The introduction of the “Gold Card” aligns with broader global shifts in residency and citizenship-by-investment programs. In 2022, the UK scrapped its investment-based residency program, while several European Union countries modified or terminated their own versions. Similarly, Caribbean nations offering citizenship-by-investment programs have introduced stricter regulations. The U.S. appears to be following suit by exploring alternative pathways for wealthy individuals seeking residency and eventual citizenship.

What This Means for EB-5 Investors​

For individuals considering the EB-5 program, this period may present an opportune time to apply. The Department of State’s upcoming Visa Bulletin indicates that priority processing remains available for certain applicants, including those from India and China. Furthermore, investors who file before September 2026 benefit from grandfathering provisions under the EB-5 Reform and Integrity Act, ensuring their applications remain protected despite potential policy changes.

Pros and Cons of the “Gold Card” Initiative​

Pros:

• Offers a faster and potentially more straightforward pathway to U.S. citizenship for ultra-wealthy individuals.
• Could attract significant foreign capital into the U.S. economy.
• May reduce fraud and mismanagement concerns associated with the EB-5 program.
• Eliminates job-creation requirements, simplifying the process for investors.

Cons:

• Lacks congressional approval, raising legal and constitutional concerns.
• May face political and public pushback due to its exclusive focus on ultra-wealthy applicants.
• Could create uncertainty for existing EB-5 investors and applicants.
• If not properly regulated, might encourage a wealth-based immigration system that lacks economic development incentives.

Final Thoughts​

President Trump’s “Gold Card” initiative represents a bold shift in U.S. immigration policy. While it may offer an attractive alternative for UHNWI investors, questions remain regarding its implementation, legality, and long-term impact. Until further details emerge, prospective EB-5 investors should carefully consider their options while the existing program remains in place.