USCIS has officially released Form I-140G, the immigrant petition for the new Gold Card Program established by Executive Order 14351. The form and instructions provide the first complete look at eligibility criteria, financial requirements, and extensive due-diligence obligations that applicants must satisfy.
While public attention has focused on the program’s financial gift thresholds, the more significant legal considerations involve Source of Funds, Path of Funds, national security vetting, and compliance standards. These requirements reflect a framework that in many ways exceeds the documentation burdens seen in the EB-5 program.
Overview of the Gold Card Program
Form I-140G allows eligible applicants to pursue permanent residence under:
- EB-1A (Extraordinary Ability)
- EB-2 NIW (Exceptional Ability + National Interest Waiver)
Petitions may be filed by an individual or by a corporation on behalf of a beneficiary.
Required Gift Contribution
- $1 million per person for individual self-petitioners, including each dependent spouse or child
- $2 million for corporations filing on behalf of a principal beneficiary
- +$1 million for each dependent in a corporate filing
Filing Fee
The filing fee is $15,000 per person, separate from the gift requirement.
When to File Form I-140G
Filings cannot be submitted immediately. Applicants must first:
- Register through trumpcard.gov
- Wait for USCIS to confirm that the submission was accepted
Only after confirmation will USCIS invite the applicant to create or log in to a MyUSCIS account to file Form I-140G. Filing is entirely online.
Major Compliance Requirement: Source of Funds
Form I-140G requires extensive, multi-year documentation proving that all gift funds originate from lawful sources. The level of required evidence is substantial and resembles — or exceeds — the requirements in the EB-5 immigrant investor program.
Applicants must identify and document all sources of capital, including:
- Income
- Sale or mortgage of property
- Business ownership or sale
- Inheritance or gifted funds
- Cryptocurrency assets
- Any other capital sources
Income-Based Funds
USCIS typically requires:
- Seven years of personal income tax returns
- Five years of complete bank statements
- Employer-issued income verification
- Evidence of stock sales, commissions, bonuses, or other earnings
Sale or Mortgage of Property
USCIS may request:
- Proof of property ownership
- Appraisal or valuation documents
- Purchase, sale, or mortgage contracts
- Evidence showing how the property was originally acquired
USCIS wants not only the sale proceeds, but also proof of the lawful origin of the money used to purchase the property.
Business Ownership
Applicants may need to provide:
- Business registration documents
- Corporate tax returns (often seven years)
- Audited financials
- Corporate bank statements
- Documentation showing how the applicant acquired ownership
Inheritance or Gifted Funds
USCIS may require:
- Evidence of relationship with the giver
- Documentation proving the giver’s funds were lawful
- Attestations from the giver
- Transfer records into the applicant’s account
USCIS expects full transparency into the donor’s financial history.
Cryptocurrency
The form explicitly requires:
- Wallet identification
- Blockchain transaction records
- Records from a regulated exchange
- Documentation showing conversion to fiat currency
Crypto must be fully traceable from origin to deposit.
Path of Funds Requirements
Separate from the source itself, USCIS also requires a complete Path of Funds — a step-by-step tracing of the movement of capital from the applicant’s accounts to the U.S. government.
Bank Transfers
Applicants must document:
- Every financial institution involved
- Dates of each transfer
- Routing and account numbers
- SWIFT/BIC/IBAN identifiers
- Bank addresses
- Statements showing outgoing and incoming transfers
Credit Card Payments
Applicants must provide:
- Pay.gov receipt
- Cardholder details
- Issuing bank information
Use of Agents
Applicants must disclose whether any consultant, migration agent, or financial intermediary helped move, organize, or advise on the funds.
National Security and High-Risk Attestations
The form includes an extensive list of attestation questions covering:
- Money laundering
- Financial crimes
- Espionage or intelligence activity
- Sanctions exposure
- Trafficking or persecution
- Foreign political affiliations
- Totalitarian or authoritarian party involvement
These questions apply not only to the applicant, but also to:
- Persons who gifted funds
- Businesses associated with the applicant
- Any party involved in transferring funds
Corporate Filings: Additional Requirements
Corporate petitioners must provide:
- Ownership structure and beneficial ownership information
- Organizational charts
- Three years of tax returns or audited financial statements
- Disclosure of foreign affiliates or government ownership
- Source and path documentation for corporate-owned assets
USCIS closely scrutinizes whether any corporate funding originates from a foreign government or state-affiliated entity.
Dependents Must Independently Qualify
Unlike typical employment-based immigrant categories, dependents under the Gold Card Program are not derivative beneficiaries.
Each dependent must:
- Provide full biographical and background information
- Undergo the same national security vetting
- Trigger an additional $1 million gift
- Trigger an additional $15,000 filing fee
Dependents are treated as full participants in the program, not add-ons.
Filing Must Be Completed Online
Form I-140G is filed exclusively online after registration and USCIS invitation. Paper submissions will not be accepted.
Conclusion
The release of Form I-140G provides the first detailed roadmap of the Gold Card Program. While the financial contribution requirements are straightforward, the real complexity lies in:
- Source of Funds documentation
- Path of Funds tracing
- National security screening
- Corporate transparency requirements
- Treatment of dependents as full financial participants
Prospective applicants should begin collecting multi-year financial documents early, particularly if their assets involve property sales, business interests, cryptocurrency, or funds originating from multiple jurisdictions.
Our office will continue monitoring developments as USCIS releases additional operational guidance. We are available to assist clients with evaluation, strategy, documentation preparation, and compliance planning.