Do not assume it can. The official gift and private charges serve different purposes and must follow the actual instructions and arrangements. The September 7, 2026 official processing fee is US$15,000 per person and nonrefundable; the principal gift is US$1,000,000 individually or US$2,000,000 corporately. Family and continuing corporate obligations are additional.
Avoid reducing one amount by an unrelated bill
No adviser’s charge guarantees approval or converts the gift into an investment expected to be returned.
The Gold Card processing fee is expressly nonrefundable, and its gift creates no asset; EB-5 capital is invested at risk in an enterprise, with any repayment depending on the offering terms and project performance. Financial planning should separate official processing amounts, the stated gift payment, document procurement, translations, medical steps, and any professional services. Before any transfer, identify the applicant, official payee, authorized payment method, amount, timing, and any stated receipt or refund terms in the controlling material. A placement fee, a reservation fee, a private fee for expedited treatment or any payment routed into the consultant's account for onward transmission to the government should be refused. If the company imposes employment-service or repayment terms, disclose them as private commercial terms and obtain appropriate independent advice before treating them as immaterial.