The Proposed USCIS Regulations Do Not Address Fraud in EB-5 Program

Any and all federal programs are subject to fraudulent actions by small groups of bad actors.  It is for this reason that each and every major federal program is accompanied by the delegation of enforcement authorities to the relevant regulator.

USCIS has spent considerable time on restructuring the USCIS program through  a series of proposed rulemakings instead of focusing  on enforcement.  Even if the totality of the USCIS  proposed structural changes were to become law they  would have virtually no impact on eliminating fraud  in the  USCIS program. What is the rationale for making structural changes through new regulations a higher priority than enforcing existing regulations?

What are your views on this matter? Feel free to make a comment below or  provide a more comprehensive analysis  and data in the Discussion Forum provided to the right of this post.

If CRE receives a threshold level of comments it will use them in developing a White Paper  which will be sent to USCIS.


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