Iran EB-5 Investors and the September 30, 2026 Grandfathering Deadline

The core question is whether an Iranian investor should file a complete I-526 or I-526E petition on or before September 30, 2026. Filing by that date grandfathers the petition under the EB-5 Reform and Integrity Act of 2022 (RIA) grandfathering provision: it stays processable even if the regional-center program is not reauthorized after September 30, 2027, and it locks the investment minimums in effect at the time of filing. The current minimums are $800,000 for set-aside and targeted-employment-area projects and $1,050,000 for non-TEA projects. A CPI-U inflation adjustment is expected to raise both effective January 1, 2027, so the minimums are expected to increase for anyone filing afterward.

For Iran specifically, the deadline pressure is amplified by funding mechanics rather than visa backlog. Iran is generally current by chargeability, but OFAC sanctions mean the lawful capital cannot simply wire from a domestic Iranian bank. It must already be outside Iran, or move through an OFAC-compliant mechanism that can require specialized sanctions counsel alongside immigration counsel. Source-of-funds documentation faces extra scrutiny to show lawful origin. Because assembling and positioning capital is the slowest step here, the realistic window to file by September 30, 2026 is shorter than the calendar suggests.

EB5Status does not provide legal, tax, or immigration advice and cannot tell you whether to file. What the data supports is a clear conclusion on sequencing: if you intend to file before the deadline, the funding work has to begin immediately. Waiting risks both a missed grandfathering window and higher minimums.

Fund transfer is the defining constraint for Iranian investors and the main reason to start now. Because OFAC sanctions block movement through the Iranian banking system, the capital intended for an EB-5 investment must already be held outside Iran, typically in a third-country account, or be moved using an OFAC-compliant mechanism. Some pathways require a specific OFAC license, which adds review time on top of the immigration timeline. This is why Iran represents the slowest funding path of any country, and why the September 30, 2026 deadline is the hardest to meet.

Beyond the transfer itself, source-of-funds preparation carries extra scrutiny. The petition must trace the lawful origin of the capital and its path to a sanctions-compliant location, which often takes longer to assemble than for investors who can wire directly from a domestic bank. Coordinating sanctions and immigration counsel together is common. Once a complete petition is filed, processing speed depends on the project type rather than country backlog: rural set-aside petitions tend to run roughly 11 to 17 months, while unreserved I-526E petitions tend to run roughly 18 to 28 months. None of that processing time begins until the funds are positioned and the petition is filed, which is the step Iranian investors should prioritize.