EB-5 for Iranian Investors

Iranian nationals face no EB-5 visa backlog based on chargeability alone. All categories (unreserved, rural, HUA, and infrastructure) are "Current" as of March 2026. However, Iranian EB-5 investors face significant additional complexity due to U.S. sanctions on Iran.

The Office of Foreign Assets Control (OFAC) sanctions prohibit most financial transactions between Iran and the United States. This means capital transfers from Iran to a U.S. EB-5 project cannot flow through the Iranian banking system. Iranian investors typically must have funds already outside Iran (in a third country bank account) or use permissible transfer mechanisms that comply with OFAC regulations.

OFAC does issue specific licenses for certain immigration related transactions, but the process is complex and requires specialized legal counsel. Investors should work with attorneys experienced in both EB-5 immigration law and OFAC sanctions compliance to navigate the regulatory landscape.

Source of funds documentation for Iranian nationals requires particular care to demonstrate that funds are not derived from sanctioned activities. The documentation must clearly establish the lawful origin and path of investment capital, with additional scrutiny expected given the sanctions environment. Funds held in third country accounts should be traceable to their original lawful source.

Consular processing for Iranian immigrant visa applicants typically occurs at a U.S. Embassy in a third country (often Abu Dhabi, Ankara, or Yerevan) as the United States does not have an embassy in Iran. The additional administrative processing (Section 221(g)) that Iranian applicants often face can add months to the consular processing timeline.

Despite these complexities, EB-5 investment is possible for Iranian nationals with proper planning and qualified legal representation. Many Iranian investors have successfully navigated the sanctions framework and completed the EB-5 process. Early engagement with specialized counsel is essential.

The September 30, 2026 grandfathering deadline applies to all investors, including Iranian nationals, preserving current investment minimums for petitions filed before that date.