Post-RIA Reality Check: How Did the Source of Funds Adjudication for Chinese EB-5 Investors Change?
CONCERNS ABOUT STRICTER CHECKS UNDER THE EB-5 REFORM AND INTEGRITY ACT LED TO CONSISTENT HANDLING OF SOURCE OF FUNDS DOCUMENTATION, ESPECIALLY FOR CHINESE INVESTORS FACING COMMON COMPLIANCE CHALLENGES.
By F. Oliver Yang
Despite initial concerns about stricter scrutiny under the EB-5 Reform and Integrity Act, adjudication patterns reveal a surprisingly consistent approach to source of funds documentation, particularly for Chinese investors navigating familiar compliance challenges.
When the EB-5 Reform and Integrity Act( RIA) took effect in 2022, industry observers braced for a dramatically more rigorous adjudication environment. The legislation introduced sweeping changes to the EB-5 visa program, including enhanced due diligence requirements, increased minimum investment amounts, and expanded source of funds( SOF) documentation
The actual approvals post- RIA indicate that the adjudication standard has been primarily in line with patterns before this law
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