November 21, 2025
The U.S. immigration system is preparing for a significant shift with the launch of the Gold Card Program, a proposed fast-track residency pathway for wealthy foreign nationals. With USCIS submitting the draft Form I-140G to the Office of Management and Budget (OMB), the program has reached a key administrative milestone and inching closer to potential implementation.
Below, we explain what the Gold Card is, how it may work, who qualifies, and what risks applicants should consider.
What Is the Gold Card Program?
The Gold Card is a new immigration initiative championed by the Trump administration. Unlike traditional investment visas such as the EB-5—where applicants invest in job-creating U.S. projects—the Gold Card operates on an “unrestricted gift” or donation model.
Key Proposed Requirements
- $1 million donation to the U.S. Treasury for individual applicants OR $2 million donation when corporate sponsors apply on behalf of employees.
- A non-refundable application fee (projected at $15,000 per applicant).
- Extensive financial and national security vetting.
The donation is not an investment, and applicants do not receive a return. Instead, the payment is used as evidence of “extraordinary ability” or “exceptional ability,” allowing the applicant to be processed through existing employment-based categories such as EB-1 or EB-2 National Interest Waiver (NIW).
USCIS Submits Draft Form I-140G: Why This Matters
The submission of Form I-140G (Draft) to the OMB is the first concrete sign that the federal government is operationalizing the new program.
The draft form outlines:
- Required biographical information
- Documentation to prove lawful source of funds
- Disclosures related to tax compliance, sanctions, and criminal history
- Evidence demonstrating the applicant’s alignment with U.S. national interests
While the form is not yet final, its release signals that USCIS is actively preparing internal procedures and compliance frameworks.
How the Application Process May Work
Although the final rule has not yet been published, current guidance suggests the following pathway:
1. Submission of Form I-140G
Applicants would file the new form along with proof of lawful funding and required disclosures.
2. Agency Review
Multiple agencies—possibly including USCIS, the Department of State, the Department of Commerce, and national security bodies—would evaluate the application.
3. Visa Eligibility Classification
Approved applicants would likely be assigned to either:
- EB-1 Extraordinary Ability, or
- EB-2 NIW (National Interest Waiver)
4. Visa Issuance or Adjustment of Status
- Applicants inside the U.S. may seek adjustment of status (pending final rules, and the visa bulletin’s quotas).
- Applicants outside the U.S. will undergo consular processing.
The Trump administration has signaled a December 18, 2025, target for launch, although this is subject to OMB approval and potential legal challenges.
Platinum Tier: What We Know So Far
A rumored “Platinum Card” tier would require a significantly higher donation—estimated at $5 million—and may provide:
- Up to 270 days of annual presence in the U.S.
- Exemption from U.S. taxation on foreign income
However, these features have not been finalized, and the program may undergo substantial changes before release. Also, because it involves serious tax implications, it is likely that Congress would need to implement this.
Who May Qualify for the Gold Card Visa?
The program is aimed at:
- Ultra-high-net-worth individuals
- Global executives
- Entrepreneurs
- Investors seeking U.S. residency
- Individuals looking for an alternative to EB-5 backlogs
Applicants must demonstrate:
- Lawful acquisition of funds
- Clean criminal and sanctions history
- No involvement in money laundering or corruption
- Compliance with global tax reporting obligations
USCIS has indicated that crypto-derived wealth will be scrutinized using enhanced verification protocols.
Potential Benefits of the Gold Card Program
- Faster residency pathway than traditional investor visas
- No requirement to create U.S. jobs
- Flexibility for applicants with complex global asset portfolios
- Predictable contribution structure (donation instead of investment risk)
For high-net-worth individuals seeking a secure and expedited immigration route, the Gold Card could become an attractive option—if finalized.
Potential Risks and Legal Challenges
Critics warn that the program faces substantial legal uncertainty.
1. Possible Court Challenges
Congress, not the executive branch, normally creates new visa categories. Critics argue that re-classifying donations as evidence of employment-based eligibility may exceed executive authority.
2. Ethical and Policy Concerns
Opponents claim the program effectively allows wealthy individuals to “buy” immigration benefits, raising fairness questions.
3. Procedural Delays
Even if the program is approved, visa backlogs, agency capacity, and security screenings may create longer timelines than advertised.
Should You Prepare Now?
If you are considering applying once the program opens, early preparation is crucial.
Prospective applicants should begin gathering:
- Complete financial records
- Proof of lawful source of funds
- Tax documentation
- Corporate ownership structures
- Cryptocurrency transaction histories (if applicable)
Because the application will undergo multi-agency scrutiny, preparation should begin months in advance.
How Our Immigration Law Firm Can Help
Our immigration attorneys can assist you with:
- Pre-qualification analysis
- Compliance preparation for Form I-140G
- Source-of-funds documentation
- National interest and extraordinary ability strategy
- Adjustment of status or consular processing
- Vetting for potential legal risks and red flags
We monitor every regulatory and policy update so that our clients receive the most accurate, strategic guidance available.
Contact Us for a Consultation
If you are considering the Gold Card program or evaluating alternative immigration pathways such as EB-1, EB-2 NIW, or EB-5, our legal team is ready to help you navigate the options.
Schedule a confidential consultation today by emailing us at josh@wildeslaw.com.
*This is an ongoing development, and this post may not be updated.