Access alone does not explain ownership or lawful source.
Identify the actual capital arrangement
Record who supplied the money and on what terms it becomes the applicant’s investment. If a gift or loan is involved, establish its lawful source and good-faith, noncircumvention conditions. Do not infer ownership solely from the ability to initiate a bank transfer.
The immigrant investor category requires an investment of the qualifying amount in a new commercial enterprise that creates at least ten full-time jobs for qualifying U.S. workers, made with capital the investor obtained lawfully, with the investor engaged in management or policy formulation. EB-5 requires qualifying capital placed at risk in a new commercial enterprise, the required job creation under the applicable model, and compliance with the immigrant process; an ordinary investment return expectation does not replace those elements. Approval leads to conditional permanent residence, and the conditions are removed only on a later petition showing that the capital remained invested and that the required jobs were created, or where permitted will be created within the applicable period.