Reid & Wise LLC issues advisory guidance as Trump Golden Card 2.0 nears launch, outlining regulatory updates, risks, and strategic considerations ahead of the December 18 deadline.
-- Reid & Wise LLC, a U.S. immigration law firm with extensive experience in investor-based and employment-based immigration, today issued a formal advisory regarding the imminent full implementation of the Trump Golden Card 2.0 program. With final regulations scheduled for release on December 18, 2025, recent actions by U.S. Citizenship and Immigration Services and the Department of Commerce confirm that the program has entered its final pre-launch phase, creating a narrow but critical decision window for prospective applicants worldwide.
According to Reid & Wise, the Trump administration introduced the Golden Card 2.0 program in September 2025 through executive action. Over the past two months, regulatory activity has accelerated. In November, USCIS released the initial draft of Form I-140G, the program’s dedicated immigrant petition, signaling that agency-level infrastructure was being established. On December 10, further milestones were reached with the launch of the official application-fee payment portal, publication of a detailed program FAQ, and release of the Office of Management and Budget–approved draft of Form I-140G accompanied by preliminary filing instructions.
“These coordinated developments indicate that the Golden Card program is moving decisively toward operational readiness,” says Fankai Oliver Yang, Esq., Chair of the Immigration Practice Group at Reid & Wise LLC. “Prospective applicants now have sufficient visibility into the structure and requirements of the program to begin informed planning, while remaining mindful of unresolved regulatory and policy risks.”
Current disclosures confirm that the Golden Card process will be conducted exclusively through the MyUSCIS online platform. All filings, supporting documentation, payments, and case-status monitoring must be completed electronically, with no paper submissions permitted. This fully digital framework represents a significant departure from traditional employment-based immigration processing and reflects an effort to facilitate expedited adjudication.
Additionally, the program provides an official inquiry channel: applicants may email goldcard@doc.gov with questions regarding filing mechanics, payments, and documentation requirements. At the same time, federal agencies confirmed that the previously discussed “Platinum Card” concept will not proceed, as its proposed tax-related incentives would require congressional authorization.
As Reid & Wise state, one of the most consequential clarifications relates to program fees and donation requirements. Under the Golden Card framework, every applicant—principal, spouse, and child—must separately pay a non-refundable application fee of US$15,000 and make a US$1 million donation. No exemptions or family-based reductions apply. For a family of three, this results in US$45,000 in application fees and US$3 million in total donations. This structure departs from longstanding U.S. immigration practice, under which dependents typically do not submit independent immigrant petitions or incur equivalent financial obligations.
“The per-applicant donation model is unprecedented in modern U.S. immigration law,” Yang notes. “Applicants should assume that the current framework will apply unless revised in the final regulations.”
The government has now outlined a multi-stage application process. Applicants must first pay the non-refundable application fee through the official payment portal, which accepts international credit cards and U.S. ACH transfers. Following payment, applicants are directed to create and verify a MyUSCIS account and submit Form I-140G online. USCIS and related agencies then initiate background and security screening, including biometrics where required. These checks are expected to take approximately two to three weeks.
Only after clearing this stage may applicants proceed with the required donation, which must be transmitted via international SWIFT transfer to a designated Department of Commerce account. Upon confirmation of receipt, applicants may advance to immigrant visa processing by filing Form DS-260. USCIS has stated that adjudication of Form I-140G is expected to take only a few weeks, significantly shorter than typical EB-1 or EB-2 processing timelines.
Corporate-sponsored Golden Card cases are subject to additional obligations, including an annual US$20,000 maintenance fee and a US$100,000 replacement fee if a sponsored employee must be substituted.
Furthermore, despite public discussion suggesting preferential treatment, the Golden Card program remains subject to existing statutory employment-based visa limits. Applicants must therefore contend with priority-date backlogs reflected in the Visa Bulletin. As of December 2025, China-born EB-1 applicants face an estimated two-year backlog, while EB-2 applicants may experience waits exceeding four years. Any attempt to elevate Golden Card cases above other employment-based petitions would conflict with current law.
Applicants may also elect to file under either the EB-1 or EB-2 National Interest Waiver classification. Given shorter backlogs and the program’s stated emphasis on extraordinary contributions, most applicants are expected to pursue EB-1 classification. Despite public statements suggesting flexibility, current guidance indicates that source-of-funds review standards will closely resemble those applied in EB-5 cases. Applicants must demonstrate the lawful origin of all funds and disclose all relevant financial holdings, including cryptocurrency assets.
Reid & Wise LLC advises that the Golden Card program carries material legal, financial, and policy risks. As an executive-action program, it remains vulnerable to judicial challenge or termination by a future administration. Financial exposure is also significant, as required donations must be made prior to completion of the immigrant visa process and are explicitly non-refundable in the event of denial.
For certain applicants, however, the program may offer strategic advantages. High-net-worth individuals who prioritize speed, procedural efficiency, and early initiation of the U.S. naturalization timeline may find the Golden Card appealing, particularly where visa backlogs are limited. By contrast, EB-5 investors generally cannot begin counting time toward citizenship until approval of the I-829 petition.
Drawing on extensive experience in complex immigration matters, Reid & Wise LLC advises prospective applicants to evaluate the Golden Card alongside established pathways such as EB-5. “The appropriate strategy depends on financial structure, risk tolerance, country of birth, and long-term objectives,” Yang says. “EB-5 continues to offer greater statutory stability, while the Golden Card may be suitable for those willing to assume higher risk in exchange for speed.”
The firm further recommends waiting until final regulations are issued on December 18 before submitting payments or applications, as certain provisions may still be revised. Early preparation of source-of-funds documentation is strongly advised, particularly in cases involving cryptocurrency, offshore transfers, or complex financial structures.
Reid & Wise LLC remains committed to providing precise, strategic counsel as the Golden Card program approaches full implementation. Applicants seeking to assess their eligibility or obtain a detailed comparison with EB-5 are encouraged to contact the firm for a personalized consultation.
For more information about Reid & Wise, or to contact, please visit https://reidwise.com/.
About Reid & Wise LLC
Reid & Wise LLC is a U.S.-based law firm with a nationally recognized immigration practice advising individuals, families, and corporations on employment-based and investor immigration matters. The firm has extensive experience with EB-1, EB-2, and EB-5 petitions and is known for its rigorous source-of-funds analysis, strategic case planning, and consistent record of successful outcomes.
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