November 19, 2025 | Investor Visas
By Richard T. Herman, Esq., Immigration Lawyer — Herman Legal Group

Quick Answer

USCIS has submitted the draft Form I-140G—the new petition for President Trump’s forthcoming Gold Card Program—to the Office of Management and Budget (OMB) for mandatory federal review. This is a key step toward meeting the December 18, 2025 implementation deadline set by presidential order.

Under the draft framework, Gold Card applicants would:

Make a $1M–$2M non-refundable gift to the United States

Pay a $15,000 non-refundable USCIS fee

Undergo rigorous lawful-source-of-funds scrutiny

Meet EB-1 Extraordinary Ability or EB-2 National Interest Waiver standards

Disclose all financial accounts, including cryptocurrency wallets that are traceable on the blockchain

For high-net-worth families and global investors, this is a fast-moving, high-stakes opportunity that demands careful planning.

👉 To discuss strategy, Book a consultation.

Fast Facts: Gold Card Snapshot

Item	Details
Program Status	Draft Form I-140G under review at *OMB*
Target Launch	December 18, 2025 (by presidential order)
Key Agencies	*USCIS* + *Department of Commerce*
Core Petition	Form I-140G (Gold Card), built on EB-1 / EB-2 NIW standards
Required Gift	$1M–$2M per applicant, depending on who files
USCIS Fee	$15,000 per applicant (non-refundable), paid via *pay.gov*
Crypto Use	Allowed, but must be fully blockchain-traceable via regulated exchanges
Post-Approval Path	Consular processing or Adjustment of Status (expected)

What Is the Gold Card Program?

The Gold Card Program is a proposed immigrant visa pathway that combines:

A major financial gift to the U.S. government, and
A merit-based immigrant petition under existing categories:
- EB-1A Extraordinary Ability
- EB-2 NIW

Unlike EB-5, which focuses on investment and job creation, the Gold Card is premised on:

A gift, not an investment
Very aggressive financial transparency
Integration with national-security, anti-fraud, and anti-money-laundering screening

The draft Form I-140G is the core petition USCIS would use to adjudicate eligibility.

To understand how this fits within immigrant employment categories, see USCIS I-140.

Step-by-Step: Proposed Gold Card Process

1. Application to the Department of Commerce

The first step is filing a Gold Card application with the Department of Commerce. This is where the gift is directed and where initial governmental review of the funds’ lawfulness and national-interest context is triggered.

2. Payment of the $15,000 Fee via pay.gov

Each applicant would pay a $15,000 non-refundable fee through the federal payment portal pay.gov. This fee is per person and is in addition to the multimillion-dollar gift.

3. Filing of Form I-140G with USCIS

After the Commerce step and fee payment, applicants (or corporate petitioners) would file Form I-140G with USCIS, under the general petition framework outlined at USCIS Forms and USCIS I-140.

USCIS would:

Evaluate eligibility under EB-1 Extraordinary Ability or EB-2 NIW standards
Conduct lawful-source-of-funds checks
Review full financial account disclosures
Screen for fraud, money laundering, terrorism financing, and sanctions issues

Financial Evidence and Crypto: New Transparency Requirements

The proposed Form I-140G radically expands what USCIS expects from high-net-worth applicants.

Comprehensive Financial Account Disclosures

The draft form would require a list of all financial accounts for you and your spouse, including:

Domestic and foreign bank accounts
Brokerage and investment accounts
Corporate accounts (if relevant)
Cryptocurrency accounts and wallets

This goes well beyond the documentation traditionally required in immigrant petitions.

Crypto Funds Must Be Blockchain-Traceable

The draft form reportedly states that:

If using crypto funds, those must be traceable through blockchain with wallet identification with a known wallet exchange through regulated financial institutions. Provide your wallet identification. USCIS may request additional evidence.

Practically, that means:

Your crypto must be traceable from a regulated exchange
Anonymous, non-KYC sources will be heavily scrutinized or rejected
You should expect USCIS (or partner agencies) to use chain-analysis tools to track the funds

Gift Amounts: $1M vs. $2M and Corporate Filings

The proposed instructions distinguish who is filing the petition:

Individual Filing for Themselves

For an individual filing Form I-140G on his or her own behalf, the required gift to the United States is $1 million 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.

So a family of four would face a $4M gift.

Corporation or Similar Entity Filing on Behalf of an Individual

If a corporation or similar entity is filing Form I-140G on behalf of an individual, the required gift is $2 million for the principal beneficiary, and $1 million per person for any accompanying spouse or children listed on this petition.

In addition, the corporate petitioner must provide:

3 years of federal tax returns
Annual reports and/or
Audited financial statements

This pushes Gold Card cases into a realm similar to complex business immigration + financial compliance work.

Post-Approval: Consular Processing vs. Adjustment of Status

Once USCIS approves Form I-140G and a visa number is available (tracked via the DOS Visa Bulletin), applicants will move into one of two paths:

1. Consular Processing (Outside the U.S.)

Most applicants abroad will proceed through the National Visa Center (NVC) and a U.S. consulate or embassy.

For a structured overview, see:

Consular Processing

2. Adjustment of Status (Inside the U.S., Expected)

The draft instructions do not yet fully address Adjustment of Status (AOS), but it is widely expected that certain non-immigrants in lawful status will be allowed to apply for a green card from inside the U.S.

For context on AOS requirements and risks, see:

Adjustment of Status

Complex cases involving past status violations, unlawful presence, or misrepresentation may intersect with waiver strategies like:

I-601A Waiver

“Platinum Card” Concept: 270 Days, $5 Million, and Taxes

The Administration has also floated a Platinum Card concept on its website, reportedly allowing:

A $5 million gift
Up to 270 days in the U.S. annually
No U.S. tax on non-U.S. income, likely keyed to the IRS Substantial Presence Test

However:

No executive order has been issued
No regulation has appeared in the Federal Register
No official form has been published on USCIS

Right now, Platinum Card details are more policy signal than legally actionable framework.

Why Ohio Investors Should Pay Attention (Cleveland, Columbus, Cincinnati, Dayton, Akron)

Ohio hosts globally connected investors, physicians, tech founders, and family business owners who may benefit from early positioning in the Gold Card Program.

Herman Legal Group provides localized, high-touch investor immigration support in:

With the December deadline looming, Ohio-based and national clients alike should begin building:

A portfolio of lawful-source documents
Crypto traceability evidence (if applicable)
A strategy for demonstrating extraordinary ability or national interest
- EB-1A Extraordinary Ability
- EB-2 NIW

Global Impact Analysis: How the U.S. Gold Card Could Reshape High-Net-Worth Migration Patterns

Most coverage of the Gold Card focuses on the fee structure and EB-1 / NIW eligibility, but very little analysis has explored how the program fits within the global mobility economy, where governments aggressively compete for ultra-rich migrants.

Why This Matters for Journalists

The Gold Card could realign global capital flows by introducing the first-ever U.S. model of high-donor immigration, competing directly with:

Portugal’s former “golden visa”
UAE’s 10-year Golden Residency
Singapore’s Global Investor Program
The U.K.’s shuttered Tier 1 Investor Visa
Canada’s Start-Up Visa and Quebec’s Investor Program (periodically suspended)

The U.S. has historically avoided this space, relying on EB-1 talent and EB-5 investment instead. The Gold Card marks the country’s first entry into the multi-million-dollar donor residency market, creating:

Potential Global Consequences

1. Capital Reallocation from Europe to the U.S.
With the EU tightening anti-money-laundering oversight, wealthy families seeking stable residencies may redirect funds from the EU to the U.S.

2. Intensified Competition With Gulf States
Qatar, the UAE, and Saudi Arabia are aggressively recruiting global wealth; a U.S. donor-based residency threatens those ecosystems.

3. Accelerated Mobility for “Silicon Triangle” Innovators
Founders moving between the U.S., Canada, and Singapore could view the Gold Card as a “premium lane” into American permanent residence.

4. A Shift Toward Philanthropy-Linked Immigration
The gift-based model could create a new category of “impact migration,” where high-net-worth individuals strategically direct capital into U.S. economic development programs.

This may become the most significant global migration shift since Portugal’s 2012 Golden Visa.

National Security Lens: The Gold Card’s Financial & Crypto Vetting Could Become a Model for Future Employment-Based Immigration

The Gold Card’s most groundbreaking (and controversial) feature is its financial transparency mandate — including full crypto wallet reporting and blockchain-based traceability.

Why This Section Matters

While the public conversation focuses on the size of the gift, the true regulatory innovation is the federal government’s new ability to:

Seamlessly integrate blockchain forensics
Require complete digital-asset transparency
Map global wealth networks
Apply intelligence-style vetting to immigration petitions

This is unprecedented in U.S. immigration.

Key Features Likely to Attract Journalists

1. Integration of Blockchain Tracing Into Immigration Vetting
For the first time, USCIS and the Department of Commerce will require:

Wallet identification
Proof of regulated-exchange sourcing
Full blockchain tracing of crypto used as part of the gift

This amounts to a mini-CFTC/FinCEN-level compliance review inside a USCIS petition.

2. Gold Card Applications May Trigger Multi-Agency Scrutiny
Journalists should note the likely interplay of:

USCIS
FinCEN
Treasury’s Office of Intelligence & Analysis
Homeland Security Investigations
OFAC (sanctions screening)

This is much deeper than EB-5’s source-of-funds checks.

3. A Future Blueprint for All EB-Category Filings
If the Gold Card’s financial review mechanisms prove successful, DHS may:

Extend blockchain tracing to other investor and employment categories
Require broader digital-asset disclosures
Incorporate anti-money-laundering audits into EB-5, E-2, L-1, and O-1
Modernize INA 212(a) financial inadmissibility standards

This is the first time federal immigration processing has directly intersected with cryptocurrency forensics — setting a potential precedent for all future employment-based visas.

“Winners and Losers”: Which U.S. Regions, Industries, and Universities Benefit Most From the Gold Card?

The public debate focuses on wealthy immigrants, but the ripple effects across U.S. cities and industries could be enormous.

Potential Winners

1. Rust Belt & Midwest Regeneration (Ohio, Michigan, Pennsylvania)
Regions like Cleveland, Columbus, Dayton, and Akron — each represented by Herman Legal Group — could see:

Increased capital inflow
Immigrant-led business formation
Medical, engineering, and AI recruiting
New venture ecosystems in advanced manufacturing

This positions Midwest cities as emerging hubs for global high-net-worth migration.

2. Universities with Research Strength
Institutions like:

Case Western Reserve
Ohio State University
Carnegie Mellon
University of Michigan

stand to gain from EB-1-caliber scientists, researchers, and innovators who leverage the Gold Card to build U.S. academic and commercialization ties.

3. Tech, AI, and Biomedical Clusters
Gold Card applicants are likely to come from sectors with:

Strong patent portfolios
Public-impact innovations
Global-scale talent

These align naturally with EB-1 and NIW immigration frameworks.

Potential Losers

1. Countries Facing Wealth Flight
Nations with fragile economies may see accelerated capital outflow from high-net-worth citizens seeking U.S. stability and mobility.

2. EB-5 Regional Centers
The Gold Card’s simplicity threatens the EB-5 model:

Faster
No job-creation requirement
No project-risk exposure

EB-5 may need to restructure to remain competitive.

3. EU and UK Investor-Migration Programs
Jurisdictions tightening AML rules may lose investor migrants to the U.S., where credibility and safety are higher.

The Gold Card isn’t just immigration — it’s an economic development catalyst reshaping which U.S. regions will thrive in the next decade.

USCIS Gold Card Program – Detailed FAQ (2025 Legal Update)

1. What is the Trump “Gold Card” program in plain English?

The Gold Card is a new, fast-track immigrant visa pathway created by presidential executive order that allows certain foreign nationals to pursue U.S. permanent residence (a green card) if they:

Make a large non-refundable “gift” to the U.S. government (generally $1M or $2M), and
Qualify under existing employment-based immigrant categories — mainly EB-1 Extraordinary Ability and EB-2 National Interest Waiver (NIW).(The White House)

The program does not create a brand-new visa category. Instead, the gift is treated as evidence that supports EB-1/EB-2 eligibility and national benefit.

For deeper background on those categories, see:

2. Is the Gold Card program already active? Can I apply today?

Not yet.

As of November 19, 2025:

USCIS has drafted Form I-140G and sent it to the OMB for required federal review.(WR Immigration)
Agencies are working toward a December 18, 2025 implementation deadline set by the Executive Order.(The White House)

You cannot file Form I-140G until:

OMB completes its review, and
USCIS / Department of Commerce formally open filings, likely with instructions posted on USCIS, USCIS Forms, and the Federal Register.

3. What is Form I-140G? How is it different from regular Form I-140?

Form I-140 is the long-standing immigrant petition for workers in EB-1, EB-2, and EB-3 categories. See: USCIS I-140.
Form I-140G is a new, Gold Card–specific petition that:(WR Immigration)
- Incorporates EB-1 / EB-2 NIW standards
- Adds Gold Card gift requirements
- Adds extensive financial disclosure and lawful-source vetting
- Includes crypto wallet tracing and national security attestations

Think of I-140G as: I-140 + gift + extreme financial transparency.

4. How much money do I have to “gift” under the Gold Card program?

Under the Executive Order and the draft I-140G instructions:(The White House)

If you file for yourself (individual filing):
- $1,000,000 per person requesting a Gold Card
- That means principal + spouse + each child each requires a separate $1M gift
If a corporation or similar entity files for you:
- $2,000,000 for the principal beneficiary
- $1,000,000 per dependent (spouse and each child)

These are non-refundable gifts, not investments. They are deposited into a Treasury fund to promote commerce and American industry under the authority of the Department of Commerce. (The White House)

5. Is this money an “investment” like EB-5? Will I get it back?

No.

The Gold Card is not an EB-5–style investment:

It is an unrestricted, non-refundable gift to the U.S. government.(The White House)
You do not retain equity or ownership tied to the gift.
You do not get the funds back if your case is denied or later revoked.

EB-5 is about investment + job creation.
Gold Card is about gift + merit-based EB-1/EB-2 eligibility.

6. What is the separate $15,000 fee and who pays it?

On top of the gift, there is a non-refundable $15,000 application/vetting fee per Gold Card applicant.(WR Immigration)

Key points:

It must be paid through the federal portal pay.gov
It is owed per person, not per family
It is non-refundable, even if the case is denied or withdrawn

You should also budget for standard government filing fees and legal fees.

7. Does paying the gift automatically guarantee a green card?

No. The Executive Order explicitly says the gift is treated as evidence, not an automatic entitlement.(The White House)

You still must:

Qualify legally under EB-1 or EB-2 NIW standards
Be admissible under U.S. immigration law
Have a visa number available according to the DOS Visa Bulletin
Clear extensive security and background checks

8. Who is the Gold Card really designed for?

From public statements and the structure of the program, it is clearly targeted at:(KPMG)

Ultra-high-net-worth individuals
Global executives / founders
Corporate leaders whose employers or holding companies can make the gifts
Individuals whose work, business activities, or philanthropy can plausibly fit EB-1 extraordinary ability or EB-2 national interest frameworks

If your profile already points toward EB-1A Extraordinary Ability or EB-2 NIW, the Gold Card may function as an accelerator, not a replacement.

9. What are the basic eligibility criteria besides money?

At a minimum, applicants must:(The White House)

Be eligible for lawful permanent residence
Be admissible (no disqualifying criminal, security, or immigration grounds, unless waivable)
Fit within EB-1 or EB-2 NIW standards
Have a visa number available (see DOS Visa Bulletin)
Pass background and security checks
Provide extensive proofs of lawful source of funds

A Gold Card gift is not a waiver of criminal, fraud, or security bars to admission.

10. Who can be included as dependents in a Gold Card case?

Dependents are expected to mirror standard employment-based immigrant rules:

Spouse of the principal applicant
Unmarried children under 21

Each dependent:

Requires their own gift amount ($1M) tied to the main petition, and
Must be admissible in their own right

Parents, siblings, and adult children are not derivative beneficiaries under standard EB-1 / EB-2 frameworks.

11. What is the difference between an individual Gold Card and a corporate Gold Card?

Based on the EO and related commentary:(The White House)

Individual Gold Card:
- The individual makes a $1M per-person gift
- Ideal for entrepreneurs, investors, or wealthy individuals acting independently
Corporate Gold Card:
- A corporation or similar entity makes a $2M gift per sponsored principal, plus $1M per dependent
- The corporation may have flexibility to reassign that “gift credit” to another employee later, under some interpretations of the EO and draft guidance

Corporate filers must submit multi-year tax returns, annual reports, and/or audited financial statements with Form I-140G.(WR Immigration)

12. What is this about listing all my financial accounts? How intrusive is it?

The draft I-140G instructions require a list of all financial accounts for you and, if applicable, your spouse — including cryptocurrency accounts.(WR Immigration)

That includes:

Domestic and foreign bank accounts
Brokerage and securities accounts
Investment and private equity accounts
Crypto wallets and exchange accounts

From a compliance perspective, you should expect scrutiny comparable to or exceeding high-risk banking and anti-money-laundering reviews.

13. How does USCIS treat cryptocurrency in Gold Card cases?

The draft form specifically states that if you are using crypto:

Funds must be traceable on the blockchain
Wallets must be tied to a known, regulated exchange
You must provide wallet identification and be prepared to give more evidence

This means:

“Privacy coins,” mixers, and unregulated sources will raise serious red flags
You may need professional blockchain tracing reports
Expect coordination with agencies charged with sanctions, money-laundering, and terror-finance enforcement

Plan to document the crypto history as carefully as you would document traditional bank transfers.

14. Will Gold Card holders be subject to U.S. taxes?

Yes, as lawful permanent residents you will generally be subject to U.S. taxation on global income, like any green card holder, and evaluated under rules such as the IRS Substantial Presence Test.

The teased Platinum Card (involving a $5M gift and up to 270 days of U.S. presence with no U.S. tax on foreign-source income) is different, and still not fully implemented — no formal rule or form exists yet.(WR Immigration)

15. What is the “Platinum Card” and how is it different from the Gold Card?

According to Administration messaging:(WR Immigration)

Gold Card → Fast-track immigrant visa (green card) in exchange for $1M / $2M gift
Platinum Card → Proposed status concept where a $5M gift could allow up to 270 days in the U.S. per year without U.S. tax on non-U.S. income

However:

No Platinum Card regulations are on USCIS or in the Federal Register
It may function more like a long-term, tax-privileged stay rather than a green card

For now, treat Platinum Card references as early policy signals, not binding law.

16. How does the Gold Card intersect with the regular EB-1 or NIW process?

The Gold Card is built on top of EB-1/EB-2 NIW, not separate from them.(The White House)

Your case is still evaluated under EB-1/EB-2 NIW legal standards
The $1M / $2M gift is treated as additional evidence of:
- Extraordinary ability
- Exceptional ability
- National interest / benefit

In practice, that means:

You still need a strong record (awards, publications, major roles, impact, etc.) for EB-1A Extraordinary Ability, or
Compelling national-interest arguments for EB-2 NIW

17. Will my country of chargeability and the Visa Bulletin still matter?

Yes.

Visa numbers for Gold Card approvals are expected to come out of the same EB-1 / EB-2 pools.(Fennemore)

That means:

Heavily backlogged countries could still face waiting periods, especially in EB-2
You will need to follow priority dates and visa availability in the DOS Visa Bulletin

Your gift does not exempt you from statutory numerical limits.

18. Will there be consular interviews? What if I’m already in the U.S.?

After Form I-140G is approved and a visa is available:

Applicants outside the U.S. will go through normal consular processing via the NVC and the local embassy or consulate. See:
- Consular Processing
Applicants inside the U.S. in lawful status may be able to file for Adjustment of Status (AOS) once USCIS clarifies procedures, likely on USCIS Forms and USCIS. For current AOS guidance, see:
- Adjustment of Status

Interviews are highly likely, given the stakes and the security focus.

19. Can someone with prior immigration violations or unlawful presence qualify?

Maybe, but it will be complicated.

Issues like:

Past unlawful presence
Misrepresentation or fraud findings
Certain criminal issues

can trigger bars to admissibility that money does not cure. Some grounds can be addressed through waivers (like I-601A Waiver) but others cannot.

Any Gold Card strategy for someone with a problematic history will require:

Careful waiver analysis
Strategic timing of consular vs AOS routes
Realistic risk assessment

20. Is this program likely to be challenged in court or changed by a future administration?

Yes, significant litigation and political pushback are likely.(Economic Policy Institute)

Risks include:

Court challenges to the legality or implementation of the EO
Regulatory changes limiting eligibility or scaling back benefits
Future administrations modifying or terminating the program

However, historically, individuals who have already been granted permanent residence often retain that status even when policy tools change — though no outcome is guaranteed.

21. How is Herman Legal Group approaching Gold Card cases, especially for Ohio investors?

Herman Legal Group is focusing on:

High-net-worth individuals and family offices
Entrepreneurs and executives already close to EB-1A Extraordinary Ability or EB-2 NIW eligibility
Ohio-based and national clients who need integrated immigration + financial compliance planning

We work with clients in:

To explore whether a Gold Card strategy fits your profile, you can:
👉 Book a consultation

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Key Takeaways

Draft Form I-140G for the Gold Card Program is under review at OMB.
The Administration is pushing toward a December 18, 2025 launch.
Applicants must make a $1M–$2M non-refundable gift plus a $15,000 USCIS fee.
Crypto can be used but must be fully traceable through regulated exchanges.
Applicants and spouses must disclose all financial accounts, including crypto wallets.
Post-approval will likely require consular processing or Adjustment of Status.
Early preparation with experienced immigration and financial counsel is essential.