By Richard T. Herman, Immigration Lawyer, Herman Legal Group

QUICK ANSWER

The Gold Card is a proposed immigration pathway allowing wealthy foreign nationals to obtain a green card through a $1 million donation (individual) or $2 million donation (corporate) to a qualifying U.S. nonprofit, university, or hospital.

The breakthrough occurred when USCIS formally transmitted draft Form I-140G to the Office of Management and Budget (OMB) for review — a mandatory step before launching a new immigration form.

Referenced sources:

USCIS Forms → USCIS Forms
OMB Review Dashboard → OMB Executive Review Dashboard

If you want to evaluate eligibility or filing strategy, schedule a review with the Herman Legal Group:

Book a Consultation → Book a Consultation

FAST FACTS

Draft Form I-140G is under OMB review
Donation amounts:
- $1M for individual petitioner
- $2M for corporate petitioners
Expected filing fee: ~$15,000
Affects wealthy immigrants, EB-5 candidates, universities, hospitals, and nonprofits
Could become the fastest path to a green card
Faces high litigation risk
Not yet active — cannot file yet
Verified updates:
- USCIS Newsroom → USCIS Newsroom

INTRODUCTION

The Trump administration’s 2025–26 immigration strategy combines aggressive enforcement with newly expanded “elite” immigration channels. The Gold Card I-140G green card program has drawn extraordinary attention because it allows qualifying donors to secure permanent residency by contributing large sums to U.S. nonprofits, universities, hospitals, and other public-benefit organizations.

The key development:
USCIS has officially transmitted draft Form I-140G to OMB for approval, which means this program is not hypothetical — it is moving toward implementation.

Government sources:

Major professional analysis confirming the OMB submission:

Fragomen Insights

If rolled out, the Gold Card would compete directly with pathways like EB-5, EB-1, NIW, and occasionally even O-1.

For personal evaluation:

Book a Consultation

1. WHAT CHANGED: USCIS SENDS DRAFT FORM I-140G TO OMB

The biggest confirmation that the Gold Card is real is the posting of draft Form I-140G to OMB’s review queue.

Why OMB review matters

Before a new immigration form can be used, the Office of Management and Budget must approve it under the Paperwork Reduction Act.

Verified source:

OMB Executive Review Dashboard

Once OMB gives the green light:

USCIS adds the form to its Forms page
USCIS updates the Policy Manual
Field officers receive training
Applications can be submitted

If published, all updates will appear at:

2. HOW THE GOLD CARD PROGRAM WOULD WORK

A. Donation Requirements

$1 million donation (individual petitioner)
$2 million donation (corporate petitioner)

Donations must be made to U.S.-based public-benefit institutions, typically 501(c)(3) nonprofits.

B. Filing Fee (~$15,000)

This would place it among the most expensive USCIS forms — justified by USCIS as necessary for “integrity reviews.”

C. Program Differences From EB-5

No job creation
No investment risk
No regional center involvement
Donation may be irrevocable
Stricter AML and source-of-funds scrutiny expected
Faster adjudication likely

To compare existing investor pathways:

EB-5 Immigrant Investor Green Card

D. Fraud, AML, and Source-of-Funds Standards

Modeled on EB-5 documentation, USCIS will likely require:

tax records
international bank statements
donor contracts
nonprofit verification
AML certification

3. WHO’S MOST AFFECTED

A. High-Net-Worth Immigrants

Includes:

global investors
EB-5 participants
entrepreneurs
H-1B, O-1, and L-1 executives seeking faster residency
dependents

B. Universities and Hospitals

Potential beneficiaries:

Cleveland Clinic
University Hospitals
The Ohio State University
Case Western Reserve University
Cincinnati Children’s Hospital
Cleveland Museum of Art
State universities

C. Corporate Petitioners

The $2M corporate-donation track may be used by:

biotech companies
research consortiums
hospitals
private universities

Employment-based green card overview:

Employment-Based Green Cards Overview

4. GOLD CARD VS. EB-5 VS. EB-1/NIW COMPARISON

Category	Gold Card (I-140G)	EB-5 Investor Visa	EB-1 / NIW
Donation / Investment	$1M–$2M donation	$800K–$1.05M investment	No major cost
Risk	Political volatility	Investment risk	RFE-heavy
Job Requirement	None	10+ jobs	None
Timeline	Expected fast	3–5 yrs	Medium
Dependents	Yes	Yes	Yes
Filing Fee	~$15k	~$11k	~$700
Legal Stability	Low	Medium	High

EB-1/NIW information:

Employment-Based Green Cards

5. LEGAL UNKNOWNS

Major unresolved issues include:

Definition of “qualifying nonprofit”
Refundability of donations
Fraud-prevention mechanisms
Whether court challenges will block implementation
Whether I-140G petitions will be grandfathered if reversed
Extent of AML vetting
Whether consular officers will follow USCIS approval

Expect ongoing updates at:

6. POLITICAL BACKLASH & EXPECTED LITIGATION

The U.S. is following in the footsteps of other countries that implemented or abandoned “golden visa” programs (Malta, UK, Portugal, Canada).

Media coverage likely to intensify:

Litigation is expected on grounds that DHS is “monetizing immigration benefits.”

7. COMPLIANCE REQUIREMENTS (EXPECTED)

Applicants will likely need:

full source-of-funds documentation
foreign tax records
donation contract
nonprofit IRS documentation
lawful immigration status (if filing I-485)

For adjustment of status guidance:

Adjustment of Status (I-485)

8. STEP-BY-STEP PROCESS (EXPECTED)

Strategic consultation → Book a Consultation
Identify qualifying institution
Negotiate donation
Prepare evidence packet
File Form I-140G once published
File I-485 or consular processing
Attend interview (if scheduled)
Receive permanent residency

9. RISKS FOR IMMIGRANTS (CRITICAL)

No guarantee of approval
Donation may be nonrefundable
Program could be frozen by court order
Increased AML scrutiny
Reversal by a future administration
Delays or RFEs could stall cases

10. OHIO ANALYSIS

Ohio could become a top Gold Card beneficiary due to:

world-class hospitals
major research universities
philanthropic growth sectors
large nonprofit institutions eligible to receive donations

This is especially relevant for:

Cleveland
Columbus
Cincinnati
Dayton
Toledo
Akron
Youngstown

11. QUOTES FROM RICHARD HERMAN

“The Gold Card program could reshape high-net-worth immigration — but with extraordinary legal risk.”

“Immigrants must be cautious: a philanthropic donation could be lost if the program stalls or is overturned.”

“The financial documentation burden for Gold Card applicants will likely mirror, or exceed, EB-5 standards.”

12. FAQ — GOLD CARD I-140G PROGRAM

1. Is the Gold Card program active right now?

No. USCIS has only submitted draft Form I-140G to OMB. Updates will appear in the USCIS Newsroom → USCIS Newsroom .

2. What exactly is the Gold Card I-140G program?

A proposed immigration pathway allowing green cards through large donations to U.S. institutions.

3. Where can I confirm the status of Form I-140G?

Through the OMB Review Dashboard → OMB Review Dashboard .

4. How much is the required donation?

$1 million for individual petitioners; $2 million for corporate petitioners.

5. Is the donation refundable if my case is denied?

There is no evidence refunds will be allowed; most donations will likely be nonrefundable.

6. Does a $1 million donation guarantee a green card?

No. USCIS may deny the case for many reasons.

7. Is this the same as the EB-5 program?

No. EB-5 requires investment + job creation; Gold Card is donation-based.

8. How is the Gold Card different from EB-1 or NIW?

EB-1/NIW are merit-based; no donations required.

9. Who can file a Gold Card petition?

Individuals or U.S. institutions (universities, hospitals, nonprofits).

10. Who benefits most from the Gold Card program?

High-net-worth immigrants, universities, hospitals, and nonprofits.

11. Will dependents (spouse + children) be included?

Yes. As with EB categories, spouses and unmarried children under 21 qualify.

12. Does USCIS have legal authority to create this category?

USCIS claims authority under employment-based immigrant visa broad definitions.

13. Will Congress need to approve the Gold Card?

No. This is a regulatory (agency-level) program.

14. Could the program be blocked by lawsuits?

Yes. High likelihood.

15. What happens if the program is frozen after I donate?

Your money may already be gone; USCIS may hold or cancel your case.

16. Is it safer than EB-5?

No. EB-5 is more stable; Gold Card is politically volatile.

17. Will USCIS require source-of-funds documentation?

Yes. Likely similar to EB-5 scrutiny.

18. What kind of documents prove source of funds?

Tax returns, bank records, business records, inheritance documents, sale agreements.

19. Can the donation be made in cryptocurrency?

Likely no or extremely restricted due to AML concerns.

20. Will USCIS interview Gold Card applicants?

Probably yes.

21. Can an H-1B worker qualify?

Yes, if they can meet the donation requirement.

22. Can O-1 or L-1 holders qualify?

Yes.

23. Can someone without status in the U.S. apply?

They may apply abroad through consular processing.

24. Can undocumented immigrants apply?

Unlikely — unlawful presence triggers multiple bars.

25. Will Gold Card donors need biometrics?

Yes.

26. Will I need a medical exam?

Yes — required for adjustment of status.

27. Can nonprofits solicit donations for this program?

Likely yes, but with strict compliance requirements.

28. What institutions qualify to receive donations?

Likely 501(c)(3) public-benefit organizations such as universities and hospitals.

29. Can I donate to a private foundation?

Unclear; depends on final rules.

30. Will churches qualify?

Uncertain; IRS and DHS criteria must be met.

31. Can foreign organizations receive the donation?

No — donations must go to U.S. institutions.

32. Will the donation be tax-deductible?

Possibly, if made to a qualifying charity and documented properly.

33. Will USCIS verify the nonprofit?

Yes — likely strict vetting.

34. How long will adjudication take?

Unknown; may be expedited.

35. Will premium processing be available?

Undetermined.

36. Will USCIS publish guidance for officers?

Yes — through the USCIS Policy Manual → USCIS Policy Manual .

37. Will consular officers approve Gold Card cases?

They must follow USCIS approval but may raise security issues.

38. Could a change in administration cancel the program?

Yes — extremely likely.

39. Would pending cases be grandfathered in?

No guarantee.

40. Could USCIS deny a case even if the donation is made?

Yes, for eligibility, admissibility, or security concerns.

41. What if the nonprofit mishandles paperwork?

The petition may be denied.

42. Will this increase fundraising competition among universities?

Yes — major institutions may race to attract donors.

43. Can corporate employers sponsor executives via the Gold Card?

Yes — through the $2 million donation track.

44. Will Gold Card holders get work authorization?

Yes — green card includes full employment authorization.

45. Will Gold Card lead to citizenship?

Yes, after holding permanent residency for the required number of years.

46. Can I apply for adjustment of status in the U.S.?

Yes — if lawfully present and eligible.
See:
Adjustment of Status (I-485)

47. Can I apply from overseas?

Yes — through consular processing.

48. Can I hire a lawyer for this?

Yes. For strategy advice, use:
Book a Consultation

49. How do Gold Card approvals differ from EB-5 approvals?

They rely on donation compliance vs. job creation compliance.

50. What is the safest time to donate?

Only after USCIS finalizes the rule AND all litigation risks are evaluated with an attorney.

KEY TAKEAWAYS

Draft Form I-140G is under OMB review
Gold Card green cards would require $1M–$2M donations
Political, legal, and refundability risks are significant
Ohio institutions may become major beneficiaries
Immigrants should conduct legal strategy reviews before donating
To explore eligibility:
Book a Consultation

Success Stories

Gold Card I-140G Million-Dollar Green Card Program: What Changed, Who Qualifies, and What Immigrants Must Know in 2025–26

Table of Contents