Integrating cryptocurrency into the
EB-5 stream
Does Zhang v. USCIS mark the new era of the source of funds
process?
By Natalia Polukhtin
W
elcomed by EB-5 community, the decision in Zhang
v. USCIS et al. 1 provides much needed guidance on
the use of loan proceeds as a source of EB-5 investment
capital. However, the Zhang decision may be interpreted
as not being about loans per se, but also as providing
opportunities in showing the source of funds for investors
who have legitimate money but do not have USCIS-friendly
documentation for those funds. The primary example of
those legitimate funds that cannot be comprehensively
documented due to the perceived anonymit y in
accumulation process is cryptocurrency.
Over a decade ago, Bitcoin star ted the trend of
cryptocurrencies entering traditional investment portfolios.
As more investors across the world accumulate their wealth
in cryptocurrencies, funds that originated from the use of
blockchain technologies are becoming a more prominent
par t of the EB5 process. Let’s identify oppor tunities
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