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EB-5 Question of the Week: Can Iranian nationals participate in the EB-5 program?

Yes, Iranian nationals are eligible to participate in the EB-5 Immigrant Investor Program.

What is the EB-5 program?

The EB-5 program of the United States provides an opportunity to foreign investors and their qualifying dependents to obtain U.S. Green Cards with an investment of $800,000 in a government pre-approved real estate project. A family including the main applicant, spouse, and children under the age of 21 can be included in one single application allowing each member of the family to receive their own Green Card. The program provides a stable and secure path to obtaining permanent resident status in the United States, which can thereafter lead to citizenship.

While Iranian nationals are eligible to participate in the EB-5 program, , due to sanctions and other political factors, there may be additional requirements and restrictions for Iranian nationals. Thus, it is important for Iranian nationals who are interested in the EB-5 program to consult with experienced EB-5 consultants and immigration attorneys who can provide guidance on the specific requirements and potential challenges associated with participating in the program. Despite these challenges, the EB-5 program can provide Iranian nationals with a pathway to permanent residency in the United States.

Compliance with U.S. financial laws and regulations

One consideration for Iranian nationals seeking to obtain their Green Cards through the EB-5 program is compliance with U.S. financial laws and regulations. Compliance with the Office of Foreign Assets Control (OFAC) regulations is mandated by U.S. laws for all entities and individuals in the country. OFAC is a federal agency under the U.S. Department of the Treasury responsible for implementing and enforcing economic and trade sanctions aligned with U.S. foreign policy and national security objectives. Sanctions have been imposed on Cuba, Iran, Sudan, North Korea, Syria, Russia, and other countries by OFAC regulations. Previously, Iranian nationals were required to apply for and obtain a “specific license” prior to transferring their investment funds to their project of choice. However, current regulations allow Iranian investors participating in the EB-5 program to transfer funds to the United States via a general license.

Nevertheless, Iranian nationals investing in the EB-5 program must confirm that their funds do not originate from an entity or person on the Specially Designated Nationals (SDN) list to avoid obtaining a specific license beforehand. Thus, it is essential to conduct a search before transferring funds to the U.S. if there is any suspicion that they might come from an SDN-listed source.

Path of funds

Another consideration for Iranian nationals participating in the EB-5 program is the transfer of funds and demonstrating the path of funds to the United States Citizenship and Immigration Services (USCIS). The EB-5 program requires all investors to show that the capital used for investment in the U.S. is from lawful sources and can be legally traced. Given international banking sanctions on Iran, it is not possible for investors to directly transfer their funds from their personal bank accounts in Iran to the project of their choice in the United States. Therefore, Iranian applicants transferring funds from Iran must use the services of an exchange house or a third party money transfer agent. While the use of a third party money transfer agent does not lead to an automatic rejection of the EB-5 application by USCIS, applicants must still be vigilant in ensuring that the transferring entity is not on the SDN list and provides sufficient documentation evidencing the path of funds.

EB-5 is a suitable option for Iranian applicants

While there may be additional considerations for Iranian applicants, the EB-5 program is a suitable immigration option for Iranian nationals. Compared to nationals of high demand countries such as India and China, EB-5 applications of Iranian nationals will be processed faster given that there are no backlogs. 

Contact our Iranian EB-5 specialists today

At The American Legal Center, we have a team of U.S. licensed lawyers specifically dedicated to the Iranian market. Our Farsi-speaking advisors are well-aware of the nuances applicable to Iranian nationals wishing to participate in the EB-5 program and can guide you in navigating this government program. We can assist you in collating the necessary documents to demonstrate the path of your funds to USCIS to increase the chances of your application’s success.

For more information on the EB-5 program and to schedule a complimentary consultation, you may contact our EB-5 specialist dedicated to Iranian nationals at +971 52 112 3786 or email

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