Unmasking the EB-5 “Combo Card” Scam: The Hidden Risks Behind False Installment Investment Schemes
The EB-5 investment immigration programme’s concurrent filing policy allows applicants to submit I-526 and I-485 together, gaining a...
The Allure — and Misuse — of Concurrent Filing
Since the implementation of reforms to the EB-5 Immigrant Investor Programme, the concurrent filing option has created a significant advantage: investors can submit their I-526 (immigrant petition) and I-485 (adjustment of status) together, and quickly receive a temporary “Combo Card” — a combined work permit and travel document.
The policy’s intent was straightforward: to give legitimate investors the ability to live, work, and travel while their case is pending. Unfortunately, in certain corners of the market, unscrupulous actors have turned this into a new breeding ground for fraud, exploiting applicants’ desire for speed and flexibility.
I. Two Faces of the Combo Card Scam
1. “Knowing Collusion” — Exploiting Loopholes Together
In this arrangement, agencies and applicants enter into an unspoken agreement: for a fraction of the EB-5 minimum investment, often a few tens of thousands of dollars, the agency will file a superficially complete I-526 petition just to trigger the issuance of a Combo Card.
The hallmarks include:
No actual $800,000 investment transferred.
Business plans that are vague, recycled, or incomplete.
Documentation that does not meet USCIS substantive requirements.
Agencies pitch it as a “win-win”: even if I-526 is ultimately denied, the applicant has “bought” several years in the US, with children attending public schools and parents accompanying them — effectively treating the EB-5 as a long-term visitor programme.
While seemingly harmless in the short term, this undermines the credibility of the EB-5 programme and invites tighter USCIS scrutiny, which in turn hurts compliant investors.
2. “Investor Deception” — Selling False Security
Here, the target is misled from the start. Agencies claim that with a $50,000 deposit and the registration of a US company, they can initiate an EB-5 direct investment application, secure a Combo Card within months, and determine the actual investment project later.
Typical sales pitches include:
“Combo Card approval in months — move to the US quickly.”
“We can package a business later; no rush now.”
“Direct investment green card in 1–3 years.”
The danger is obvious: investors mistake the Combo Card for a sign that their green card is on track, when in fact the card has nothing to do with the I-526 adjudication outcome.
II. Why These Schemes Are Doomed to Fail
1. Combo Card ≠ Green Card
The Combo Card is issued after I-485 filing, granting temporary work and travel rights. At this stage, USCIS has not yet reviewed the I-526 petition’s investment details or business plan. Approval of the card does not mean approval of the EB-5 petition.
2. The Business Plan Is the Heart of I-526 Approval
Under the precedent case Matter of Ho, EB-5 petitions must be accompanied by a comprehensive, credible, and executable business plan, including:
Market analysis and competitive assessment.
Detailed financial projections.
Job creation timelines and staffing structure.
Capital structure and use of funds.
Material changes to the business plan after filing can result in outright denial. The “file now, find a project later” pitch violates these requirements and is a clear red flag.
3. Installment Investment Must Be Time-Bound
While EB-5 regulations allow investment to be “in progress,” USCIS expects the full amount to be transferred within a reasonable timeframe. Industry practice suggests completing funding within six months as the safest approach. Extended delays signal a lack of genuine commitment and can trigger rejection.
III. How to Protect Yourself
To avoid falling prey to the Combo Card trap, remember:
The Combo Card is not a green card — it offers no guarantee of EB-5 approval.
Your I-526 must include a complete, credible business plan from the start; retroactive fixes are risky and often fatal to the case.
Be sceptical of “low-cost, quick green card” offers — especially those built on deferred investments, placeholder projects, or vague timelines.
Conclusion: No Shortcuts in EB-5
In US investment immigration, shortcuts are rarely what they seem. The EB-5 is a long-term, compliance-driven process requiring thorough preparation, credible investment, and professional guidance. The promise of “minimal investment, maximum benefit” is not an opportunity — it’s a risk-laden illusion.
By understanding the limits of the Combo Card and respecting the integrity of the EB-5 process, investors can avoid costly detours and keep their American dream firmly within reach.
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